Overflow System PM2.5, PM10 and Total PM

Overflow System PM2.5, PM10 and Total PM Emission Factors for Cotton Gin E using Method 201a with a PM2.5 Cyclone Part of the National Characterization of Cotton Gin Particulate Matter Emissions Project

Report ID: 15-PM2.5-GE-201a September 2014 Submitted to: U.S. Environmental Protection Agency

Submitted by: Dr. Michael Buser (contact) Dept. of Biosystems and Agricultural Engineering Oklahoma State University 113 Agricultural Hall Stillwater, OK 74078 (405) 744-5288 [email protected] Mr. Thomas Moore Dept. of Biosystems and Agricultural Engineering Oklahoma State University 117 Agricultural Hall Stillwater, OK 74078 (903) 477-2458 [email protected]

, Ph.D.

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Dr. Derek Whitelock Southwestern Cotton Ginning Research Laboratory USDA Agricultural Research Service 300 E College Dr. Mesilla Park, NM 88047 (575) 526-6381 [email protected]

Acknowledgments: Funding Sources: California Cotton Growers and Ginners Association Cotton Foundation Cotton Incorporated Oklahoma State University San Joaquin Valley Air Pollution Study Agency Southeastern Cotton Ginners Association Southern Cotton Ginners Association Texas Cotton Ginners Association Texas State Support Group USDA Agricultural Research Service USDA NIFA Hatch Project 02882

Air Quality Advisory Group: California Air Resources Board Missouri Department of Natural Resources North Carolina Department of Natural Resources San Joaquin Valley Air Pollution Control District Texas A&M University Biological and Agricultural Engineering Department Texas Commission on Environmental Quality US Environmental Protection Agency – Air Quality Analysis Group US Environmental Protection Agency – Air Quality Modeling Group US Environmental Protection Agency – Office of Air Quality Planning and Standards US Environmental Protection Agency – Process Modeling Research Branch, Human Exposure and Atmospheric Sciences Division US Environment Protection Agency Region 4 US Environment Protection Agency Region 9 USDA NRCS National Air Quality and Atmospheric Change Team

Cotton Gin Advisory Group: California Cotton Ginners and Growers Association Cotton Incorporated National Cotton Council National Cotton Ginners Association Southeastern Cotton Ginners Association Southern Cotton Ginners Association Texas Cotton Ginners Association Texas A&M University Biological and Agricultural Engineering Department

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Table of Contents Introduction ....................................................................................................................................... 4 Answered Submitter Review ............................................................................................................ 5 Answered Regulatory Agency Review ............................................................................................. 6 Outlier Tests ...................................................................................................................................... 7 OSU Technical Report ..................................................................................................................... 8 Field and Laboratory Data .............................................................................................................. 30 Process Calibration Documents ..................................................................................................... 50 Dry Gas Meter Calibration.............................................................................................................. 53 Type "S" Pitot Tube Calibration ..................................................................................................... 58 Nozzle Inspection............................................................................................................................ 63 Cyclonic Flow Evaluation............................................................................................................... 68 Chain of Custody ............................................................................................................................ 70 Acknowledgements ......................................................................................................................... 72

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Introduction The submitted information corresponds to the National Characterization of Cotton Gin Particulate Matter Emissions Project conducted by Oklahoma State University and USDA Agricultural Research Service. This report contains PM2.5, PM10 and total PM data for the overflow system for cotton Gin E that was collected using Method 201a with a PM2.5 cyclone. As part of the National Characterization of Cotton Gin Particulate Matter Emissions Project, there were several individual submitted reports for the cotton gin overflow system. These test reports were separated by cotton gin and testing method. For the overflow system there will be 4 Method 17 reports for total PM; 4 Method 201a without a PM2.5 sizing cyclone reports for total PM and PM10; 4 Method 201a with a PM2.5 sizing cyclone reports for total PM, PM10 and PM2.5 and 4 Method 17 coupled with particle size analyses for PM10 and PM2.5. The cotton gin identifiers for these reports are Gin A, Gin C, Gin D and Gin E. Our submitter review and suggested regulatory review ITRs were developed using the procedures described by the Eastern Research Group (2013). Our answered submitter and regulatory review questions are located on pages 5 and 6. Information corresponding to the regulatory review questions has been highlighted within the reports with the associated questions attached as comments. To see these comments, hover the cursor over or click on the highlighted portions of text. If there are any questions regarding the submitted information, please contact Dr. Michael Buser ([email protected]). Table I.1- Submitter and suggested regulatory ITRs for Gin E, Overflow System, Method 201a with a PM2.5 cyclone. PM Subset Run 1 Run 2 Run 3 Average

Submitter Review 79 79 79 79

Regulatory Review 100 100 100 100

Total PM Emission Factor (lbs/bale) 0.012 0.016 0.017 0.015

Regulatory Review 100 100 100 100

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PM10 Emission Factor (lbs/bale) 0.010 0.011 0.012 0.011

Regulatory Review 100 100 100 100

PM2.5 Emission Factor (lbs/bale) 0.002 0.002 0.002 0.002

Answers to Submitter Review Questions

1

2 3 4 5 6 7 8 9 10 11 12 13 14 15 16

Submitter Data Quality Rating Score Supporting Documentation Provided Response As described in ASTM D7036-12 Standard Practice for Competence of Air Emission Testing Bodies, does the testing firm meet the criteria as an AETB or is the person in charge of the field team a QI for the type of testing conducted? A certificate from an independent organization (e.g., Stack Testing Accreditation Council (STAC), Yes California Air Resources Board (CARB), National Environmental Laboratory Accreditation Program (NELAP)) or self declaration provides documentation of competence as an AETB. Is a description and drawing of test location provided? Yes Has a description of deviations from published test methods been provided, or is there a statement that deviations were not required to obtain data representative of typical Yes facility operation? Is a full description of the process and the unit being tested (including installed Yes controls) provided? Has a detailed discussion of source operating conditions, air pollution control device operations and the representativeness of measurements made during the test been Yes provided? Were the operating parameters for the tested process unit and associated controls Yes described and reported? Is there an assessment of the validity, representativeness, achievement of DQO's and Yes usability of the data? Have field notes addressing issues that may influence data quality been provided? Yes Dry gas meter (DGM) calibrations, pitot tube and nozzle inspections? Yes Was the Method 1 sample point evaluation included in the report? Yes Were the cyclonic flow checks included in the report? Yes Were the raw sampling data and test sheets included in the report? Yes Did the report include a description and flow diagram of the recovery procedures? Yes Was the laboratory certified/accredited to perform these analyses? Yes Did the report include a complete laboratory report and flow diagram of sample Yes analysis? Were the chain-of-custody forms included in the report? Yes

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79

Answers to Regulatory Agency Review Questions

14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34

Agency Data Quality Rating Score Supporting Documentation Provided Response As described in ASTM D7036-12 Standard Practice for Competence of Air Emission Testing Bodies, does the testing firm meet the criteria as an AETB or is the person in charge of the field team a QI for the Yes type of testing conducted? A certificate from an independent organization (e.g., STAC, CARB, NELAP) or self declaration provides documentation of competence as an AETB. Was a representative of the regulatory agency on site during the test? Yes Is a description and drawing of test location provided? Yes Is there documentation that the source or the test company sought and obtained approval for deviations from the published test method prior to conducting the test or that the tester's assertion that deviations Yes were not required to obtain data representative of operations that are typical for the facility? Were all test method deviations acceptable? N/A Is a full description of the process and the unit being tested (including installed controls) provided? Yes Has a detailed discussion of source operating conditions, air pollution control device operations and the Yes representativeness of measurements made during the test been provided? Is there documentation that the required process monitors have been calibrated and that the calibration is Yes acceptable? Was the process capacity documented? Yes Was the process operating within an appropriate range for the test program objectives? Yes Were process data concurrent with testing? Yes Were data included in the report for all parameters for which limits will be set? Yes Did the report discuss the representativeness of the facility operations, control device operation, and the measurements of the target pollutants, and were any changes from published test methods or process and Yes control device monitoring protocols identified? Were all sampling issues handled such that data quality was not adversely affected? N/A Was the DGM pre-test calibration within the criteria specified by the test method? Yes Was the DGM post-test calibration within the criteria specified by the test method? Yes Were thermocouple calibrations within method criteria? Yes Was the pitot tube inspection acceptable? Yes Were nozzle inspections acceptable? Yes Were flow meter calibrations acceptable? Yes Were the appropriate number and location of sampling points used? (Method 1) Yes Did the cyclonic flow evaluation show the presence of an acceptable average gas flow angle? Yes Were all data required by the method recorded? Yes Were required leak checks performed and did the checks meet method requirements? Yes Was the required minimum sample volume collected? Yes Did probe, filter, and impinger exit temperatures meet method criteria (as applicable)? N/A Did isokinetic sampling rates meet method criteria? Yes Was the sampling time at each point greater than 2 minutes and the same for each point? Yes Was the recovery process consistent with the method? Yes Were all required blanks collected in the field? Yes Where performed, were blank corrections handled per method requirements? Yes Were sample volumes clearly marked on the jar or measured and recorded? Yes Was the laboratory certified/accredited to perform these analyses? Yes Did the laboratory note the sample volume upon receipt? Yes

35

If sample loss occurred, was the compensation method used documented and approved for the method?

1 2 3 4 5 6 7 8 9 10 11 12 13

36 37 38 39 40 41 42 43 44 45 46 47

Were the physical characteristics of the samples (e.g., color, volume, integrity, pH, temperature) recorded and consistent with the method? Were sample hold times within method requirements? Does the laboratory report document the analytical procedures and techniques? Were all laboratory QA requirements documented? Were analytical standards required by the method documented? Were required laboratory duplicates within acceptable limits? Were required spike recoveries within method requirements? Were method-specified analytical blanks analyzed? If problems occurred during analysis, is there sufficient documentation to conclude that the problems did not adversely affect the sample results? Was the analytical detection limit specified in the test report? Is the reported detection limit adequate for the purposes of the test program? Do the chain-of-custody forms indicate acceptable management of collected samples between collection and analysis?

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N/A Yes N/A Yes Yes Yes N/A N/A Yes N/A Yes Yes Yes

100

Outlier Tests The following residual plots compare the overflow system test run emission factor values included in this report with those from other cotton gin tests that used Method 201a with a PM2.5 cyclone for PM2.5, Method 201a with and without a PM2.5 cyclone for PM10 and Method 17 and 201a with and without a PM2.5 cyclone for total PM. The highlighted points in the graphs indicate data included in this report.

Residuals

Overflow System PM2.5 Residuals 2.0 1.5 1.0 0.5 0.0 -0.5 -1.0 -1.5 -2.0 0

2

4

6

8

10

12

14

Test Runs

Overflow System PM10 Residuals

Residuals

1.0 0.5 0.0 -0.5 -1.0 -1.5 0

5

10

15

20

25

30

Test Runs

Residuals

Overflow System Total PM Residuals 1.5 1.0 0.5 0.0 -0.5 -1.0 -1.5 0

5

10

15

20

Test Runs

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25

30

35

40

OSU Technical Report OSU12-57 Ver. 2.0 – Overflow System PM2.5 Emission Factors and Rates for Cotton Gins Note: Contains field and lab data for Gin E only.

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ABSTRACT This report is part of a project to characterize cotton gin emissions from the standpoint of stack sampling. In 2006, EPA finalized and published a more stringent standard for particulate matter with diameter nominally less than or equal to 2.5 µm (PM2.5). This created an urgent need to collect additional cotton gin emissions data to address current regulatory issues, because current EPA AP-42 cotton gin PM2.5 emission factors do not exist. The objective of this study was the development of PM2.5 emission factors for cotton gin overflow systems based on the EPA-approved stack sampling methodology, Method 201A. The project plan included sampling seven cotton gins across the cotton belt. Key factors for selecting specific cotton gins included: 1) facility location (geographically diverse), 2) industry representative production capacity, 3) typical processing systems and 4) equipped with properly designed and maintained 1D3D cyclones. Three of the seven gins had overflow systems that the exhaust airstreams were not combined with other major systems. One gin sampled had an overflow system that the exhaust was combined with a trash handling system prior to the cyclone. In terms of capacity, the three gins were typical of the industry, averaging 27.5 bales/h during testing. Some test runs were excluded from the test averages because they failed to meet EPA Method 201A Test criteria. Also, other test runs, included in the analyses, had cotton lint fibers that collected in the ≤ 10 µm and/or ≤ 2.5 µm samples. This larger lint material can impact the reported emissions data, but EPA Method 201A does not suggest methods to account for these anomalies. Average measured overflow system PM2.5 emission factor based on the three tests (9 total test runs) was 0.0040 kg/227-kg bale (0.0088 lb/500-lb bale). The overflow system average emission factors for PM10 and total particulate were 0.018 kg/bale (0.040 lb/bale) and 0.041 kg/bale (0.090 lb/bale), respectively. The overflow system PM2.5 emission rate from test averages ranged from 0.027 to 0.21 kg/h (0.059-0.47 lb/h). The ratios of overflow system PM2.5 to total particulate, PM2.5 to PM10, and PM10 to total particulate were 9.7, 21.7, and 44.7%, respectively.

INTRODUCTION In 2006, the U.S. Environmental Protection Agency (EPA) finalized a more stringent standard for particulate matter with a particle diameter less than or equal to a nominal 2.5-m (PM2.5) aerodynamic equivalent diameter (CFR, 2006). The cotton industry’s primary concern with this standard was that there were no published cotton gin PM2.5 emissions data. Cotton

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ginners’ associations across the cotton belt, including the National, Texas, Southern, Southeastern, and California associations, agreed that there was an urgent need to collect PM2.5 cotton gin emissions data to address the implementation of the PM2.5 standards. Working with cotton ginning associations across the country and state and federal regulatory agencies, Oklahoma State University and USDA-Agricultural Research Service (ARS) researchers developed a proposal and sampling plan that was initiated in 2008 to address this need for additional data. This report is part of a series that details PM2.5 cotton gin emissions measured by stack sampling. Each manuscript in the series addresses a specific cotton ginning system. The systems covered in the series include: unloading, 1st stage seed-cotton cleaning, 2nd stage seedcotton cleaning, 3rd stage seed-cotton cleaning, overflow, 1st stage lint cleaning, 2nd stage lint cleaning, combined lint cleaning, cyclone robber, 1st stage mote, 2nd stage mote, combined mote, mote cyclone robber, mote cleaner, mote trash, battery condenser and master trash. This report focuses on overflow systems. There are published PM10 (particulate matter with a particle diameter less than or equal to a nominal 10-µm aerodynamic equivalent diameter) and total particulate, but not PM2.5, emission factors for cotton gins in EPA’s Compilation of Air Pollution Emission Factors, AP-42 (EPA, 1996a, 1996b). The AP-42 average PM10 emission factor for the overflow fan was 0.012 kg (0.026 lb) per 217-kg (480-lb) equivalent bale with a range of 0.0020 to 0.017 kg (0.0045-0.038 lb) per bale. The AP-42 average total particulate emission factor was 0.033 kg (0.071 lb) per bale with a range of 0.0050 to 0.059 kg (0.011-0.13 lb) per bale. These PM10 and total factors were each based on four tests and were assigned quality ratings of D; the second lowest possible rating. Seed cotton is a perishable commodity that has no real value until the fiber and seed are separated (Wakelyn et al., 2005). Cotton must be processed or ginned at the cotton gin to separate the fiber and seed, producing 227-kg (500-lb) bales of marketable cotton fiber. Cotton ginning is considered an agricultural process and an extension of the harvest by several federal and state agencies (Wakelyn et al., 2005). Although the main function of the cotton gin is to remove the lint fiber from the seed, many other processes also occur during ginning, such as cleaning, drying, and packaging the lint. Pneumatic conveying systems are the primary method of material handling in the cotton gin. As material reaches a processing point, the conveying air is separated and emitted outside the gin through a pollution control device. The amount of dust

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emitted by a system varies with the process and the condition of the material in the process. Cotton ginning is a seasonal industry with the ginning season lasting from 75 to 120 days, depending on the size and condition of the crop. Although the trend for U.S. cotton production remained generally flat at about 17 million bales per year during the last 20 years, production from one year to the next often varied greatly for various reasons, including climate and market pressure (Fig. 1). The number of active gins in the U.S. has not remained constant, steadily declining to less than 700 in 2011. Consequently, the average volume of cotton handled by each gin has risen and gin capacity has increased to an average of about 25 bales per hour across the U.S. cotton belt (Valco et al., 2003, 2006, 2009, 2012).

Figure 1. Annual U.S. cotton production, active U.S. gins, and average ginning volume (bales per gin) (NASS, 1993-2012).

Typical cotton gin processing systems include: unloading system, dryers, seed-cotton cleaners, gin stands, overflow collector, lint cleaners, battery condenser, bale packaging system, and trash handling systems (Fig. 2); however, the number and type of machines and processes vary from gin to gin. Each of these systems serves a unique function with the ultimate goal of ginning the cotton to produce a marketable product. Raw seed cotton harvested from the field is

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compacted into large units called “modules” for delivery to the gin. The unloading system removes seed cotton either mechanically or pneumatically from the module feed system and conveys the seed cotton to the seed-cotton cleaning systems. Seed-cotton cleaning systems dry the seed cotton and remove foreign matter prior to ginning. Ginning systems also remove foreign matter and separate the cotton fiber from seed. Lint cleaning systems further clean the cotton lint after ginning. The battery condenser and packaging systems combine lint from the lint cleaning systems and compress the lint into dense bales for efficient transport. Gin systems produce some type of non-lint by-products or trash, such as rocks, soil, sticks, hulls, leaf material, and short or tangled immature fiber (motes), as a result of processing the seed cotton or lint. These streams of by-products must be removed from the machinery and handled by trash collection systems. These systems typically further process the by-products (i.e.; mote cleaners) and/or consolidate the trash from the gin systems into a hopper or pile for subsequent removal.

Figure 2. Typical modern cotton gin layout (Courtesy Lummus Corporation, Savannah, GA).

Overflow systems (Fig. 3) follow the seed-cotton cleaning systems and are used to help

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maintain proper flow of seed-cotton to the gin stands. Seed-cotton drops from the last stage of seed-cotton cleaning into the conveyor distributor where it is distributed to the extractor feeders that meter cotton to each gin stand (cotton gins typically split the seed-cotton among multiple, parallel gin stands). Excess seed cotton in the conveyor distributor is conveyed to the overflow system storage hopper, recirculated pneumatically, and dropped back into the conveyor distributor via a screened separator as needed. The airstream from the screened separator of the overflow system continues through a centrifugal fan to one or more particulate abatement cyclones. The material handled by the overflow system cyclones typically includes soil, small leaf, and lint fiber (Fig. 4).

Figure 3. Typical cotton gin overflow system layout (Courtesy Lummus Corporation, Savannah, GA).

Cyclones are the most common particulate matter abatement devices used at cotton gins. Standard cyclone designs used at cotton ginning facilities are the 2D2D and 1D3D (Whitelock et al., 2009). The first D in the designation indicates the length of the cyclone barrel relative to the cyclone barrel diameter and Figure 4. Photograph of typical trash captured by the overflow system cyclones.

the second D indicates the length of the cyclone cone relative to the cyclone barrel diameter. A

standard 2D2D cyclone (Fig. 5) has an inlet height of D/2 and width of D/4 and design inlet velocity of 15.2 ± 2 m/s (3000 ± 400 fpm). The standard 1D3D cyclone (Fig. 5) has the same inlet dimensions as the 2D2D or may have the original 1D3D inlet with height of D and width

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D/8, but has a design inlet velocity of 16.3 ± 2 m/s (3200 ± 400 fpm). The objective of this study was the development of PM2.5 emission factors for cotton gin overflow systems with cyclones for emissions control based on EPA-approved stack sampling methodologies.

Figure 5. 2D2D and 1D3D cyclone schematics.

METHODS Two advisory groups were established for this project. The industry group consisted of cotton ginning industry leaders and university and government researchers. The air quality group included members from state and federal regulatory agencies, and university and government researchers. These groups were formed to aid in project planning, gin selection, data analyses, and reporting. The project plan was described in detail by Buser et al. (2012). Seven cotton gins were sampled across the cotton belt. Key factors for selecting specific cotton gins included: 1) facility location (geographically diverse), 2) industry representative production capacity, 3) typical processing systems and 4) equipped with properly designed and maintained 1D3D cyclones. . Operating permits, site plans, and aerial photographs were

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reviewed to evaluate potential sites. On-site visits were conducted on all candidate gins to evaluate the process systems and gather information including system condition, layout, capacities, and standard operation. Based on this information, several gins from each selected geographical region were selected and prioritized based on industry advisory group discussions. Final gin selection from the prioritized list was based on crop limitations and adverse weather events in the region. Based on air quality advisory group consensus, EPA Other Test Method 27 (OTM27) was used to sample the overflow system at each gin. When testing for this project began in 2008, OTM27 was the EPA method for determination of PM10 and PM2.5 from stationary sources. In December 2010, OTM27 was replaced with a revised and finalized Method 201A (CFR, 2010). Since the revised Method 201A grew out of OTM27, since the two methods were similar to the point that EPA stated in an answer to frequently asked questions for Method 201A (EPA, 2010) that “If the source was using OTM 27 (and 28) for measuring either PM10 or PM2.5 then using the revised reference methods Method 201A (and 202) should not be a concern and should give equivalent results.”, and since OTM27 is no longer an EPA method that can be cited, the revised Method 201A will be cited in this manuscript. To sample PM2.5, the particulate laden stack gas was withdrawn isokinetically (the velocity of the gas entering the sampler is equal to the velocity of the gas in the stack) through a PM10 sizing cyclone and a PM2.5 sizing cyclone, and then collected on an in-stack filter (Fig. 6). The methods for retrieving the filter and conducting acetone washes of the sizing cyclones are described in detail in Method 201A (CFR, 2010). The mass of each fraction size was determined by gravimetric analysis and included: > 10 µm (PM10 sizing cyclone catch acetone wash); 10 to 2.5 µm (PM10 sizing cyclone exit acetone wash and PM2.5 sizing cyclone catch acetone wash); and ≤ 2.5 µm (PM2.5 sizing cyclone exit acetone wash and filter). The PM2.5 mass was determined by adding the mass of particulates captured on the filter and the ≤ 2.5 µm wash. The PM10 mass was determined by adding the PM2.5 mass and the mass of the 10 to 2.5 µm wash. Total particulate was determined by adding the PM10 mass and the mass of the > 10 µm wash.

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Figure 7 shows the performance curves for the PM10 and PM2.5 sizing cyclones. To measure both PM10 and PM2.5, Method 201A requires selecting a gas sampling rate in the middle of the overlap zone of the performance curves for both sizing cyclones. For this study, the method was specifically used to collect filterable PM2.5 emissions (solid particles emitted by a source at the stack and captured on the filter [CFR, 2010]). The PM10 sizing cyclone was used to scrub larger particles from the airstream to minimize their impact on the PM2.5 sizing cyclone. Thus, the gas sampling rate was targeted to optimize the PM2.5 cyclone performance. Only one stack from each system was tested. For systems with multiple stacks, it was assumed that emissions from each stack of the system were equivalent and the total emissions were calculated by multiplying the measured emissions rates by the total number of cyclones used to control the process tested (EPA, 1996a). To obtain reliable results, the same technician from the same certified stack sampling company (Reliable Emissions Measurements, Auberry, CA), trained and experienced in stack sampling cotton gins, conducted the tests at all seven cotton gins. All stack sampling equipment, including the sizing cyclones, were purchased from Apex Instruments (Fuquay-Varina, NC) and met specifications of Method 201A. The sampling media were 47 mm Zefluor filters (Pall Corporation, Port Washington, NY) and the sample recovery and analytical reagent was American Chemical Society certified acetone (A18-4, Fisher Chemical, Pittsburgh, PA – assay ≥ 99.5%). Filters and wash tubs and lids were pre-labeled and pre-weighed and stored in sealed containers at the USDA-ARS Air Quality Lab (AQL) in Lubbock, TX, and then transported to each test site. Prior to testing, the certified stack testing technician conducted calibrations and checks on all stack sampling equipment according to EPA

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Method 201A.

Figure 7. Acceptable sampling rate for combined cyclone heads (CFR, 2010). Cyclone I = PM10 sizing cyclone and Cyclone IV = PM2.5 sizing cyclone.

Each cyclone tested was fitted with a cyclone stack extension that incorporated sampling ports and airflow straightening vanes to eliminate the cyclonic flow of the air exiting the cyclone (Fig. 8). The extensions were designed to meet EPA criteria (EPA, 1989) with an overall length of 3 m (10 ft) and sampling ports 1.2-m (48-in) above straightening vanes and 0.9-m (36-in) upstream from the extension exit. The tests were conducted by the certified stack sampling technician in an enclosed sampling trailer at the base of the cyclone bank (Fig. 9). Sample retrieval, including filters and sampler head acetone washes, was conducted according to Method 201A. After retrieval, filters were sealed in individual Petri dishes and acetone washes were dried on-site in a conduction oven at 49°C (120°F) and then sealed with pre-weighed lids and placed in individual plastic bags for transport to the AQL in Lubbock, TX for gravimetric analyses. During testing, bale data (ID number, weight, and date/time of bale pressing) were either manually recorded by the bale press operator or captured electronically by the gin’s computer system for use in calculating emission factors in terms of kg/227-kg bale (lb/500-lb bale). Emission factors and rates were calculated in accordance with Method 201A and ASAE Standard S582 (ASABE, 2005).

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Figure 8. Schematic and photographs of stack extensions with sampling ports and staightening vanes (rail attached to extension above sampling port, at right, supports sampling probe during testing traverse).

All laboratory analyses were conducted at the AQL. All filters were conditioned in an environmental chamber (21 ± 2oC [70 ± 3.6oF]; 35 ± 5% RH) for 48 h prior to gravimetric analyses. Filters were weighed in the environmental chamber on a Mettler MX-5 microbalance (Mettler-Toledo Inc., Columbus, OH – 1 µg readability and 0.9 µg repeatability) after being passed through an anti-static device. The MX-5 microbalance was leveled on a marble table and housed inside an acrylic box to minimize the effects of air currents and vibrations. To reduce recording errors, weights were digitally transferred from the microbalance directly to a spreadsheet. Technicians wore latex gloves and a particulate respirator mask to avoid contamination. AQL procedures required that each sample be weighed three times. If the standard deviation of the weights for a given sample exceeded 10 μg, the sample was reweighed. Gravimetric procedures for the acetone wash tubs were the same as those used for filters.

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Figure 9. Clockwise from top right: cotton gin stack sampling with air quality lab trailer and technicians on lifts; certified stack sampling technician in the trailer control room conducting tests; sample recovery in trailer clean room; technician operating the probe at stack level.

In addition to gravimetric analyses, each sample was visually inspected for unusual characteristics, such as high cotton lint content or extraneous material. Digital pictures were taken of all filters and washes for documentation purposes prior to further analyses. After the laboratory analyses were completed, all stack sampling, cotton gin production, and laboratory data were merged.

RESULTS Three of the seven gins had overflow systems that the exhaust airstreams were not combined with other major systems. One gin sampled had an overflow system that the exhaust was combined with a trash handling system prior to the cyclone. The overflow systems sampled were typical for the industry. The overflow systems at gins A and E were similar (Fig. 10). Excess seed cotton in the conveyor distributor dropped into the overflow system hopper where it was picked up and pneumatically conveyed to the overflow system screened separator. The seedcotton was separated from the conveying airstream by the separator and dropped back into the conveyor distributor. The conveying air from the overflow system separator then passed through a fan and exhausted through one or more cyclones. Gin C utilized two, separate and parallel,

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overflow systems with separate fans and emissions control cyclones (Fig. 11). It is not unusual at gins for exhaust airstreams from different systems to be combined before the fan and cyclone(s). The gin C overflow systems exhaust airstreams were combined with a relatively minor system (extractor feeder dust) before the fan. The overflow system at gin D was similar to the systems at gins A and E, except material from a significant trash system (mote trash) was combined with the exhaust airstream of the system. Since the mote trash system combined with the gin D overflow system could significantly impact the overflow system emissions, the data for the gin D system was not included in the system averages in Tables 2, 3, 4, and 5.

Figure 10. Single stream/single fan overflow system schematic (gins A, D, and E).

Figure 11. Split stream/double fan overflow system schematic (gin C).

All overflow systems sampled utilized 1D3D cyclones to control emissions, but there were some cyclone design variations among the gins (Table 1). Gins C and D split the system exhaust flow between two cyclones in a dual configuration (side-by-side as opposed to onebehind-another). The system airstream for gins A and E was exhausted through a single cyclone. Inlets on all the overflow cyclones were inverted 1D3D type, except gin D that had 2D2D inlets. Expansion chambers were present on overflow cyclones at gins A and D, and gins C and E had standard cones. All of the cyclone variations outlined above are shown in Fig. 12 and, if properly designed and maintained, are recommended for controlling cotton gin emissions (Whitelock et al., 2009).

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Table 1. Abatement device configuration for overflow systems tested. Gin

Cyclone Type

A

1D3D

C

1D3D

D

1D3D

Inlet Designz inverted 1D3D inverted 1D3D

Systems per Gin

Cyclones per Gin

Configuration

1

1

Single

2

4

Dual

standard

hopper

2D2D

1

2

Dual

expansion chamber

hopper

Cone Design expansion chamber

Trash exits toy hopper

inverted 1 1 Single standard auger 1D3D z Inverted 1D3D inlet has duct in line with the bottom of the inlet y Systems to remove material from cyclone trash exits: hopper = large storage container directly under cyclone trash exit; auger = enclosed, screw-type conveyor E

1D3D

Table 2 shows the test parameters for each Method 201A test run for the overflow systems sampled. The average ginning rate was 27.5 bales/h and ranged from 23.0 to 35.5 bales/h (based on 227-kg [500-lb] equivalent bales). The capacity of gins sampled was representative of the industry average, approximately 25 bales/h. The 1D3D cyclones were all operated with inlet velocities within design criteria, 16.3 ± 2 m/s (3200 ± 400 fpm), except the test runs at gin A that were outside the design range, due to limitations in available system adjustments.

Figure 12. Cyclone design variations for the tested systems (left to right): dual configuration that splits flow between identical 1D3D cyclones with 2D2D inlets; 1D3D cyclone with an inverted 1D3D inlet; 1D3D cyclone with 2D2D inlet and expansion chamber; 1D3D cyclone with 2D2D inlet and standard cone.

There are criteria specified in EPA Method 201A for test runs to be valid for PM2.5, PM10, or total particulate measurements (CFR, 2010). Isokinetic sampling must fall within EPA defined ranges (100 ± 20%) for valid PM2.5 and PM10 test runs. All tests met the isokinetic

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criteria (Table 2). To use the Method 201A to also obtain total filterable particulate, sampling must be within 90 to 110% of isokinetic flow. This criterion was met in all test runs. The PM2.5 aerodynamic cut size must fall within EPA defined ranges (2.50 ± 0.25 m) for valid PM2.5 test runs. PM2.5 cut size criteria was met in all tests. The PM10 aerodynamic cut size must fall within EPA defined ranges (10.0 ± 1.0 m) for valid PM10 test runs. PM10 cut size criteria was met only in the third test run at gin A; thus the data associated with the run was the only valid PM10 data. Sampling rates ranged from 10.7 to 12.0 standard l/min (0.379-0.425 standard ft3/min) (Table2). The stack gas temperatures ranged from 15 to 38oC (59-101oF). The sampling method documentation (CFR, 2010) warns that the acceptable gas sampling rate range is limited at the stack gas temperatures encountered during this project’s testing, as indicated by the narrow difference between the solid lines in Figure 7 for the temperatures listed above. These stack gas characteristics justified targeting the PM2.5 cut size criteria and treating the PM10 cut size criteria as secondary. PM2.5 emissions data (ginning and emission rates and corresponding emission factors) for the overflow systems are shown in Table 3. The system average PM2.5 emission factor was 0.0040 kg/bale (0.0088 lb/bale). The test average emission factors at each gin ranged from 0.00075 to 0.0085 kg (0.0017-0.019 lb) per bale and PM2.5 emission rates ranged from 0.027 to 0.21 kg/h (0.059-0.47 lb/h). PM10 emissions data (ginning and emission rates and corresponding emission factors) for the overflow systems are shown in Table 4. The PM10 emission factor based on the single test run was 0.018 kg/bale (0.040 lb/bale) and the emission rate for the single test run from gin A was 0.41 kg/h (0.90 lb/h). Total particulate emissions data (ginning and emission rates and corresponding emission factors) for the overflow systems are shown in Table 5. The system average total particulate emission factor was 0.041 kg/bale (0.090 lb/bale). The test average emission factors ranged from 0.0068 to 0.082 kg (0.015 to 0.18 lb) per bale. Test average total particulate emission rates ranged from 0.24 to 2.00 kg/h (0.53-4.40 lb/h). The ratios of PM2.5 to total particulate, PM2.5 to PM10, and PM10 to total particulate were 9.7, 21.7, and 44.7%, respectively (ratios calculated using tables 3, 4, and 5 may vary slightly from those listed due to rounding).

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Table 2. Cotton gin production data and stack sampling performance metrics for the overflow systems. Test Gin Run A 1 2 3 Test Average

Ginning Rate, bales/hz 23.7 26.1 22.3 24.0

Cyclone Inlet Velocity, m/s fpm 21.9 4304 21.7 4264 18.3 3606 20.6 4058

Isokinetic Aerodynamic Cut Sampling, Size D50, % PM2.5, µm PM10, µm 99 2.58 11.3w 103 2.53 11.2w 107 2.30 10.6

Sampling Rate slpm scfm 10.7 0.380 11.0 0.389 12.0 0.425

Stack Temperature °C °F 15 59 17 63 20 68

C

1 2 3 Test Average

23.6 23.6 21.8 23.0

15.5 15.8 15.3 15.5

3052 3108 3021 3060

94 94 98

2.48 2.46 2.44

11.2w 11.2w 11.1w

10.7 10.9 11.0

0.379 0.384 0.389

26 27 29

78 81 84

D

34.0 34.3 35.0 34.4

15.5 15.0 15.4 15.3

3058 2959 3022 3013

101 95 95

2.51 2.48 2.41

11.3w 11.2w 11.0

10.9 11.0 11.3

0.386 0.390 0.399

33 33 33

92 92 91

E

37.2 32.6 36.6 35.5

15.9 15.9 15.0 15.6

3130 3121 2958 3070

93 97 103

2.61 2.48 2.46

11.5w 11.2w 11.1w

10.9 11.3 11.4

0.384 0.401 0.404

38 38 38

100 101 101

1 2 3 Test Averagex 1 2 3 Test Average

System Average 27.5 17.3 3396 z 227 kg (500 lb) equivalent bales y slpm = standard l/m, scfm = standard ft3/m x Omitted from the system average because exhaust airstream combined with trash system exhaust w Did not meet PM10 (10.0 ± 1.0 µm) aerodynamic cut size criteria

The overflow system total particulate emission factor average for this project was about 1.27 times the EPA AP-42 published value for the overflow fan, which is an equivalent system to the overflow system (EPA, 1996a, 1996b). The total particulate emission factor range determined by this project and the AP-42 emission factor range overlapped. The overflow system PM10 emission factor from the single test run from gin A was 1.55 times the EPA AP-42 published value for the overflow fan. The measured PM10 emission factor was higher than the range of the AP-42 emission factor data.

Page 23 of 72

Table 3. PM2.5 emissions data for the overflow systems. Test Run 1 2 3 Test Average (n=3)

Ginning Rate, bales/hz 23.7 26.1 22.3 24.0

1 2 3 Test Average (n=3)

23.6 23.6 21.8 23.0

0.051 0.071 0.063 0.062

0.11 0.16 0.14 0.14

0.0022 0.0030 0.0029 0.0027

0.0048 0.0066 0.0064 0.0059

1 2 3 Test Average (n=3)y

34.0 34.3 35.0 34.4

0.23 0.12 0.12 0.15

0.50 0.26 0.26 0.34

0.0067 0.0035 0.0034 0.0045

0.015 0.0076 0.0075 0.010

1 2 3 Test Average (n=3)

37.2 32.6 36.6 35.5

0.026 0.024 0.030 0.027

0.058 0.053 0.066 0.059

0.00070 0.00073 0.00082 0.00075

0.0015 0.0016 0.0018 0.0017

Gin A

C

D

E

Emission Rate, kg/h lb/h 0.21 0.47 0.38 0.84 0.041 0.091 0.21 0.47

Emission Factor, kg/balez lb/balez 0.0090 0.020 0.015 0.032 0.0018 0.0041 0.0085 0.019

0.0040 0.0088 System Average (n=3) 27.5 227 kg (500 lb) equivalent bales y Omitted from the system average because exhaust airstream combined with trash system exhaust.

z

Figure 13 shows an example of samples recovered from a typical overflow system test run. Often, there are cotton lint fibers, which have cross-sectional diameters much greater than 2.5 m, in the cotton gin cyclone exhausts. Therefore, it is not unusual to find lint fiber in the > 10 µm wash from Method 201A. However, in the atypical sample shown in Figure 14, lint fibers passed through the PM10 and PM2.5 cyclones and collected in the 10 to 2.5 µm and ≤ 2.5 µm washes, and on the filter. This type of material carryover can bias the gravimetric measurements and impact reported PM2.5 emission data. EPA Method 201A does not suggest methods to account for these anomalies. Thus, no effort was made to adjust the data reported in this manuscript to account for these issues.

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Table 4. PM10 emissions data for the overflow systems. Test Run 1x 2x 3 Test Average (n=1)

Ginning Rate, bales/hz 23.7 26.1 22.3 24.0

1x 2x 3x Test Average (n=0)

23.6 23.6 21.8 23.0

0.64 0.50 0.40

1.40 1.09 0.87

0.027 0.021 0.018

0.059 0.046 0.040

1x 2x 3 Test Average (n=1)y

34.0 34.3 35.0 34.4

1.43 1.19 1.31 1.31

3.16 2.63 2.88 2.88

0.042 0.035 0.037 0.037

0.093 0.077 0.082 0.082

1x 2x 3x Test Average (n=0)

37.2 32.6 36.6 35.5

0.16 0.16 0.20

0.36 0.34 0.44

0.0044 0.0048 0.0054

0.010 0.011 0.012

Gin A

C

D

E

Emission Rate, kg/h lb/h 0.58 1.27 1.03 2.27 0.41 0.90 0.41 0.90

Emission Factor, kg/balez lb/balez 0.024 0.054 0.040 0.087 0.018 0.040 0.018 0.040

0.018 0.040 System Average (n=1) 27.5 227 kg (500 lb) equivalent bales y Omitted from the system average because exhaust airstream combined with trash system exhaust. x Test run omitted from test average emission rates and factors because the aerodynamic cut size (10.0 ± 1.0 µm) was not met z

Page 25 of 72

Table 5. Total particulate emissions data for the overflow systems.

Test Run 1 2 3 Test Average (n=3)

Ginning Rate, bales/hz 23.7 26.1 22.3 24.0

1 2 3 Test Average (n=3)

23.6 23.6 21.8 23.0

0.96 0.76 0.61 0.78

2.12 1.68 1.35 1.72

0.041 0.032 0.028 0.034

0.090 0.071 0.062 0.074

1 2 3 Test Average (n=3)y

34.0 34.3 35.0 34.4

1.96 1.81 2.05 1.94

4.33 4.00 4.52 4.28

0.058 0.053 0.059 0.056

0.127 0.117 0.129 0.124

37.2 32.6 36.6 35.5

0.20 0.23 0.28 0.24

0.45 0.51 0.63 0.53

0.0055 0.0071 0.0078 0.0068

0.012 0.016 0.017 0.015

Gin A

C

D

E

1 2 3 Test Average (n=3)

Emission Rate, kg/h lb/h 1.96 4.33 2.64 5.82 1.38 3.05 2.00 4.40

Emission Factor, kg/balez lb/balez 0.083 0.183 0.101 0.223 0.062 0.136 0.082 0.181

0.041 0.090 System Average (n=3) 29.2 227 kg (500 lb) equivalent bales y Omitted from the system average because exhaust airstream combined with trash system exhaust.

z

Figure 13. Typical EPA Method 201A filter and sampler head acetone washes from the overflow. Clockwise from top left: > 10 µm wash, 10 to 2.5 µm wash, ≤ 2.5 µm wash and filter.

Figure 14. Atypical EPA Method 201A filter and sampler head acetone washes from the overflow system with lint in all three washes and on the filter. Clockwise from top left: > 10 µm wash, 10 to 2.5 µm wash, ≤ 2.5 µm wash and filter.

Page 26 of 72

SUMMARY Seven cotton gins across the U.S. cotton belt were stack sampled using EPA Method 201A to fill the data gap that exists for PM2.5 cotton gin emissions data. Three of the seven gins had overflow systems that the exhaust airstreams were not combined with other major systems. One gin sampled had an overflow system that the exhaust was combined with a trash handling system prior to the cyclone. The tested systems were similar in design and typical of the ginning industry. All the systems were equipped with 1D3D cyclones for emissions control with some slight variations in inlet and cone design. In terms of capacity, the three gins were typical of the industry, averaging 27.5 bales/h during testing. Some test runs were excluded from the test averages because they failed to meet EPA Method 201A Test criteria. Also, other test runs, included in the analyses, had cotton lint fibers that collected in the ≤ 10 µm and/or ≤ 2.5 µm samples. This larger lint material can impact the reported emissions data, but EPA Method 201A does not suggest methods to account for these anomalies. Average measured overflow system PM2.5 emission factor based on three gins tested (9 total test runs) was 0.0040 kg/227-kg bale (0.0088 lb/500-lb bale). The overflow system PM10 emission factor, based on a single test run, and the overflow system average total particulate emission factor were 0.018 kg/bale (0.040 lb/bale) and 0.041 kg/bale (0.090 lb/bale), respectively. The gin test average PM2.5 and total particulate emission rates ranged from 0.027 to 0.21 kg/h (0.059-0.47 lb/h) and 0.24 to 2.00 kg/h (0.53-4.40 lb/h), respectively. The PM10 emission rate for the single test run was 0.41 kg/h (0.90 lb/h). The ratios of overflow system PM2.5 to total particulate, PM2.5 to PM10, and PM10 to total particulate were 9.7, 21.7, and 44.7%, respectively. These data are the first published data to document PM2.5 emissions from overflow systems at cotton gins.

Page 27 of 72

REFERENCES American Society of Agricultural and Biological Engineers (ASABE). 2005. Cotton Gins – Method of Utilizing Emission Factors in Determining Emission Parameters. ASAE S582 March 2005. American Society of Agricultural and Biological Engineers, St. Joseph, MI. Buser, M.D., D.P. Whitelock, J.C. Boykin, and G.A. Holt. 2012. Characterization of cotton gin particulate matter emissions—Project plan. J. Cotton Sci. 16:105–116. Code of Federal Regulations (CFR). 2006. National ambient air quality standards for particulate matter; final rule. 40 CFR, Part 50. U.S. Government Printing Office, Washington, D.C.. Code of Federal Regulations (CFR). 2010. Method 201A – Determination of PM10and PM2.5emissions from stationary sources (Constant sampling rate procedure). 40 CFR 51 Appendix M. Available at http://www.epa.gov/ttn/emc/promgate/m-201a.pdf (verified 2 Jan. 2013). Environmental Protection Agency (EPA). 1989. Particulate sampling in cyclonic flow. U.S. Environmental Protection Agency, Washington, DC. Available online at http://www.epa.gov/ttn/emc/guidlnd/gd-008.pdf (verified 2 Jan. 2013). Environmental Protection Agency (EPA). 1996a. Emission factor documentation for AP-42, Section 9.7, Cotton Ginning, (EPA Contract No. 68-D2-0159; MRI Project No. 4603-01, Apr. 1996). Environmental Protection Agency (EPA). 1996b. Food and agricultural industries: Cotton gins. In Compilation of air pollution emission factors, Volume 1: Stationary point and area sources. Publ. AP-42. U.S. Environmental Protection Agency, Washington, DC. Environmental Protection Agency (EPA). 2010. Frequently asked questions (FAQS) for Method 201A [Online]. Available at http://www.epa.gov/ttn/emc/methods/method201a.html (verified 01 Jan. 2013). National Agricultural Statistics Service (NASS).1993-2012. Cotton Ginnings Annual Summary [Online]. USDA National Agricultural Statistics Service, Washington, DC. Available at http://usda.mannlib.cornell.edu/MannUsda/viewDocumentInfo.do?documentID=1042 (verified 2 Jan. 2013). Valco, T.D., H. Ashley, J.K. Green, D.S. Findley, T.L. Price, J.M. Fannin, and R.A. Isom. 2012. The cost of ginning cotton – 2010 survey results. p. 616–619 In Proc. Beltwide Cotton

Page 28 of 72

Conference., Orlando, FL 3-6 Jan. 2012. Natl. Cotton Counc. Am., Memphis, TN. Valco, T.D., B. Collins, D.S. Findley, J.K. Green, L. Todd, R.A. Isom, and M.H. Wilcutt. 2003. The cost of ginning cotton – 2001 survey results. p. 662–670 In Proc. Beltwide Cotton Conference., Nashville, TN 6-10 Jan. 2003. Natl. Cotton Counc. Am., Memphis, TN. Valco, T.D., J.K. Green, R.A. Isom, D.S. Findley, T.L. Price, and H. Ashley. 2009. The cost of ginning cotton – 2007 survey results. p. 540–545 In Proc. Beltwide Cotton Conference., San Antonio, TX 5-8 Jan. 2009. Natl. Cotton Counc. Am., Memphis, TN. Valco, T.D., J.K. Green, T.L. Price, R.A. Isom, and D.S. Findley. 2006. Cost of ginning cotton – 2004 survey results. p. 618–626 In Proc. Beltwide Cotton Conference., San Antonio, TX 3-6 Jan. 2006. Natl. Cotton Counc. Am., Memphis, TN. Wakelyn, P.J., D.W. Thompson, B.M. Norman, C.B. Nevius, and D.S. Findley. 2005. Why Cotton Ginning is Considered Agriculture. Cotton Gin and Oil Mill Press 106(8), 5-9. Whitelock, D.P., C.B. Armijo, M.D. Buser, and S.E. Hughs. 2009 Using cyclones effectively at cotton gins. Appl. Eng. Ag. 25:563–576.

Page 29 of 72

Gin E Field and Laboratory Data

Page 30 of 72

Gin: E Exhaust: #3-Overflow 1D3D Date: 2010

Emission Factor (lbs/bale)

Emission Rate (lbs/hr)

Based on EPA Method OTM27

Based on EPA Method OTM27

Total PM

Total PM

Run 1 Run 2 Run 3 Average

0.0120 0.0156 0.0171 0.0149

Run 1 Run 2 Run 3 Average

PM10

0.4481 0.5093 0.6262 0.5279

PM10 X Run 1 X Run 2 X Run 3 Average

0.0097 0.0105 0.0119

Run 1 0.3616 Run 2 0.3439 Run 3 0.4351 Average PM2.5

PM2.5 Run 1 Run 2 Run 3 Average

0.0015 0.0016 0.0018 0.0017

Run 1 Run 2 Run 3 Average

PM10-2.5

0.0576 0.0528 0.0661 0.0588

PM10-2.5 Run 1 Run 2 Run 3 Average

PM2.5/PM10 Run 1 Run 2 Run 3 Average PM2.5/TSP Run 1 Run 2 Run 3 Average PM10/TSP Run 1 Run 2 Run 3 Average

0.0082 0.0089 0.0101

Run 1 0.3039 Run 2 0.2911 Run 3 0.3690 Average

15.9% 15.4% 15.2%

12.9% 10.4% 10.6% 11.1% 80.7% 67.5% 69.5%

X: Run omitted from all dependent averages PM 10 ISO or D50 not met

Page 31 of 72

E OTM METHOD 27 FIELD DATA SUMMARY #3-Overflow 1D3D

Run #1

Run #2

Run #3

ø - Start of Run, time

13:53

14:38

15:22

ø - End of Run, time

14:29

15:08

15:53

Vlc - Volume of water collected, ml

0.0

0.0

0.0

Vm - Gas volume, meter cond., dcf

12.498

10.737

11.440

Y - Meter calibration factor

1.001

1.001

1.001

Pbar - Barometric pressure, in. Hg

29.70

29.70

29.70

Pg - Stack static pressure, in. H2O

-0.27

-0.25

-0.27

ˆH - Avg. meter press. diff., in. H2O

0.500

0.510

0.504

Tm - Absolute meter temperature, °R

537.4

539.4

541.7

12.2160

10.4561

11.0942

Bws - Water vapor part in gas stream

0.016

0.016

0.016

CO2 - Dry concentration, volume %

0.00

0.00

0.00

O2 - Dry concentration, volume %

0.0

0.0

0.0

Md - Mole wt. stack gas, dry, g/mole

28.838

28.838

28.838

Ms - Mole wt. stack gas, wet, g/gmole

28.664

28.664

28.664

Cp - Pitot tube coef., dimensionless

0.840

0.840

0.840

ˆp - Avg. of sq. roots of eachˆp

0.570

0.568

0.538

Ts - Absolute stack Temp. °R

559.9

560.8

560.9

3.14

3.14

3.14

33.21

33.12

31.38

5,762

5,738

5,436

2.074E-04

2.074E-04

2.074E-04

34.56

28.40

29.92

11.49

11.16

11.11

92.9

97.2

103.3

1

1

1

Vm(std) - Standard sample gas vol., dscf

A - Area of stack, square feet Vs - Stack Gas Flow, ft/sec Qstd - Volumetric flow rate, dscfm An - Area of nozzle, square feet ø - Sampling time, minutes DP50 - Cut size, microns I - Isokinetic variation, percent Sts - Stacks per system

REM PM-10, 2.5 - 2008

Page 32 of 72

E OTM METHOD 27 FIELD DATA SUMMARY #3-Overflow 1D3D

Run #1

Run #2

Run #3

AVERAGE

Qstd - Volumetric flow rate, dscfm

5,762

5,738

5,436

5,645

Vm(std) - Standard sample gas vol., dscf

12.2160

10.4561

11.0942

11.2555

DP50 - Cut size, microns 10µ

11.49

11.16

11.11

11.25

DP50 - Cut size, microns 2.5µ

2.61

2.48

2.46

2.52

Bale/hr - Total 500 lb Bales per hr

37.2

32.6

36.6

35.5

>10 µ - Total PM g

0.0014

0.0023

0.0029

0.0022

>10 µ - Total PM gr/dscfm

0.0018

0.0034

0.0041

0.0031

>10 µ - Total PM lb/hr

0.087

0.165

0.191

0.1477

>10 µ - Total PM lb/bale

0.0023

0.0051

0.0052

0.0042

10 µ -2.5 µ - PM-10 - 2.5 g

0.0049

0.0040

0.0057

0.0049

10 µ -2.5 µ - PM-10 gr/dscf

0.0062

0.0059

0.0079

0.0067

10 µ -2.5 µ - PM-10 lb/hr

0.304

0.291

0.369

0.321

10 µ -2.5 µ - PM-10 lb/bale

0.0082

0.0089

0.0101

0.0091

< 2.5 µ - PM-2.5 g

0.0009

0.0007

0.0010

0.0009

< 2.5 µ - PM-2.5 gr/dscf

0.0012

0.0011

0.0014

0.00122

< 2.5 µ - PM-2.5 lb/hr

0.058

0.053

0.066

0.059

< 2.5 µ - PM-2.5 lb/bale

0.0015

0.0016

0.0018

0.0017

TPM - Total PM g

0.0072

0.0070

0.0097

0.0080

TPM - Total PM gr/dscf

0.0091

0.0104

0.0134

0.0110

TPM - Total PM lb/hr

0.448

0.509

0.626

0.53

TPM - Total PM lb/bale

0.0120

0.0156

0.0171

0.0149

REM PM-10, 2.5 - 2008

Page 33 of 72

E #3-Overflow 1D3D OTM METHOD 27 RESULTS Run #1

Run #2

Run #3

Average

Total Particulate Per Cyclone Total gr/dscf Total lb/hr Total lb/bale

0.0091 0.45 0.0120

0.0104 0.51 0.0156

0.0134 0.63 0.0171

0.0110 0.53 0.0149

Total Particulate Per System Total lb/hr Total lb/bale

0.45 0.012

0.51 0.016

0.63 0.017

0.53 0.015

< 10 µ Results per Cyclone - 10 µ gr/dscf - 10 µ (lb/hr) - 10 µ (lb/Bale)

0.0073 0.36 0.0097

0.0070 0.34 0.0105

0.0093 0.44 0.0119

0.0079 0.38 0.0107

< 10 µ Results per System - 10 µ (lb/hr) - 10 µ (lb/Bale)

0.36 0.010

0.34 0.011

0.44 0.012

0.38 0.011

< 2.5 µ Results per Cyclone - 2.5 µ gr/dscf - 2.5 µ (lb/hr) - 2.5 µ (lb/Bale)

0.0012 0.06 0.0015

0.0011 0.05 0.0016

0.0014 0.07 0.0018

0.0012 0.06 0.0017

< 2.5 µ Results per System - 2.5 µ (lb/hr) - 2.5 µ (lb/Bale)

0.06 0.002

0.05 0.002

0.07 0.002

0.06 0.002

Average Bales/hr

37.24

32.62

36.58

35.48

Cyclone Flow-Rates Vs Acfm Dscfm

33.21 6,260 5,762

33.12 6,242 5,738

31.38 5,916 5,436

32.57 6,139 5,645

Cyclone Inlet Velocity Vsfm

3130

3121

2958

3070

System Flow-Rates Acfm Dscfm

-

-

-

6,139 5,645

Number of Cyclones in System REM PM-10, 2.5 - 2001

Page 34 of 72

1

PRE - TEST DATA & CALCULATIONS Plant: Location: Cyclone Dia (in.): Pbar: Run-Time, Ø:

E 48.00 29.70 30

Meter Factor: 1.001 Meter Factor: 1.894 Pre-test Leak Check: 0.002

Unit: Cyclones in System: Bales/hr: Static Sp: Pitot Factor: % H2O:

in Hg min Y ¯H@ cfm

#3-Overflow 1D3D Date: Std Temp (Tstd): 1 Std Pressure: 37.24 dcO2: -0.27 in water dcCO2: 0.84 Cp dcN2: 0.025 Bws* 2.5%

¯H + 50 °F: 0.421

Closest Nd: 0.195

¯p min + 50°F: 0.120

V ft/sec min: 21.06

Ø: 30.0

¯p max + 50°F: 0.513

V ft/sec max: 43.50

Dwell Time Const. 5.05 Meter Volume: 11.7

Stack Area pSa: 3.14

¯H - 50 °F: 0.604

¯p min: 0.131

Acfm: 6494

¯p min - 50°F: 0.144

¯p max: 0.560

pTs Stack: 96.2

¯p max - 50 °F: 0.615

dscfm 0.390

Vn/Vs x 100: 97.16 EPA 201A: TEST DATA & CALCULATIONS Test Run Data

Ts

Tm °F

Tm °F

¯P

Delta H

Meter Volume

No.

°F

"H2O

Time

°F

Inlet

Outlet

"H2O

"H2O

Cubic Feet

6

92 95 95 95 96

0.530 0.420 0.380 0.300 0.350

0.00 3.07 6.35 9.50 12.36

99.0 99.0 99.0 100.0 100.0

77 77 77 77 77

77 77 77 77 77

0.370 0.420 0.390 0.320 0.300

0.500 0.500 0.500 0.500 0.500

Initial Reading 110.430 Run Start Time 13:53

96 96 97 97 98

0.250 0.380 0.420 0.330 0.370

15.12 17.65 20.72 24.04 27.19

99.0 100.0 100.0 100.0 101.0

77 78 77 78 78

77 78 77 78 78

0.250 0.370 0.430 0.390 0.250

0.500 0.500 0.500 0.500 0.500

100 97 96.2

0.280 0.250 0.355

29.72 32.24 34.56

101.0 101.0 99.9

78 78

78 78

0.250 0.210 0.329

0.500 0.500 0.500

5 4 3 2 1

33.47

Ps in Hg: 29.68

Elapsed

6

3.07

pVs, ft/sec: 34.45

¯P

1

Sd in cfm**

Delta H: 0.500

Stack Temp

2

%

pMs: 28.57

Pre-Test Data

4

79.09

pMd: 28.84

Point

3

Lab#: 810-087

°F in Hg % %

Meter Temp: 75.0 °F Stack Dia: 24.00 Pitot Leak Check: OK Post-test Leak Check: 0.003 EPA 201A - 10u & 2.5u: PRE - TEST CALCULATIONS pµs: 184.72 Ideal Nd: 0.192 Point 1 Ø: pQs: 0.41651 Input Nd: 0.195 Vn ft/sec:

Delta P1 - Run: 0.370

5

9/16/2010 68 29.92 20.90 0.01

77.4

Impinger Weights, grams Final

1 2 3 Total: 0.0 4 PM - Weights - Blank Corrected >10µ Wt:

Run End Time 14:29 Final Reading 122.928

10µ: 10µ Wt:

Run End Time 15:53 Final Reading 145.345

10µ:

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(Vmsl