2005 Annual Report 1.What major problem or issue is being resolved and how are you resolving it (summarize project aims and objectives)? How serious is the problem? What does it matter? (This project was formed in FY05 at the request of the National Program Staff. Previous research was conducted under Project No. 6208-21410-005-00D, Harvesting and ginning processes to enhance the profitability of stripper cotton). Agricultural operations are encountering difficulties complying with current air pollution regulations for particulate matter (PM). These regulations are based on the National Ambient Air Quality Standards (NAAQS), which set maximum concentration limits for PM in the ambient air. PM is currently regulated in terms of particle diameters less than or equal to a nominal 10 um aerodynamic equivalent diameter (AED), referred to as PM10; however, current legislation is underway to replace the PM10 standard with a standard that regulates PM with a diameter less than or equal to a nominal 2.5 um AED, referred to as PM2.5, and PM with particle diameters between 2.5 and 10 um AED, referred to as PMcoarse. Compliance with the PM NAAQS is determined by either property line sampling or dispersion modeling. Modeling requires emission rates that are determined from EPA's list of emission factors (AP-42) or from source sampling. The current EPA AP-42 provides PM10 emission factors for some agricultural operations such as cotton gins, but does not include PM2.5 or PMcoarse emission factors. Not only is there a limited amount of data documenting the expected PM emission being emitted from agricultural operations, but data documenting PM emission reductions associated with the extensive number best management or conservation management plans is virtually non-existent. All property line and source sampling for compliance purposes require the use of EPA approved samplers. Ideally, these samplers would produce an accurate measure of the pollutant. For instance, a PM10 sampler would produce an accurate measure of PM less than or equal to 10 um (true PM10). However, samplers are not perfect and errors are introduced due to established tolerances for sampler performance characteristics and the interaction of the particle size and sampler performance characteristics. These errors result in over-sampling that can significantly impact agricultural operations that typically generate dust with a mass median diameter (MMD) greater than 10 um AED, forcing the operations to comply with more stringent regulations than urban type sources that typically generate dust with MMD less than 10 um AED. For example, if the PM10 property line sampler concentration measurements from two industries are exactly the same and if 50% of industry A's total PM (characterized by a MMD of 10 um and a geometric standard deviation (GSD) of 1.5) entering the sampler is less than 10 um (i.e., true PM10) and 16% of industry B's PM (characterized by a MMD of 20 um and a GSD of 2.0) entering the sampler is less than 10 um, then 50% of industry A's PM can potentially reach the alveolar region of the lungs, as compared to 16% of industry B's PM. Therefore, under the current method of regulating PM10, both industries A and B appear to be emitting the same levels of PM10 when in fact industry B is emitting 68% {(50-16)/50}less true PM10 than industry A. Since the emphasis of the primary NAAQS is to protect public health, then in the previous scenario the two industries are not equally regulated. Therefore, in order to achieve equal regulation among differing industries, PM10 and PM2.5 measurements must be based on true measurements. The focus of this project plan is to establish a highly interactive research program that addresses agricultural air quality compliance related issues, with an emphasis on particulate matter. These issues include, but are not limited to:. 1)determining the errors associated with particulate matter stack and ambient air samplers (samplers that are currently being used to determine the particulate matter concentrations that are emitted by various sources);. 2)abatement device evaluation, modification, and development (methods of reducing particulate matter emissions);. 3)development of novel methods and procedures for determining particulate matter emissions from agricultural sources in an effort to minimize sampling errors;. 4)determining true PM10 and PM2.5 emission factors for cotton gins and identifying potential covariates that can affect these emission factors;. 5)evaluating the indoor air quality associated with cotton gins and evaluating various methods of reducing indoor air emissions; and. 6)determining true PM10 and PM2.5 emission factors for production related operations (i.e., tillage, harvesting, etc.) and estimated particulate matter reductions associated with various best management practices. Other agricultural industries (general production operations, cattle feed yards, dairies, etc.) are currently facing similar, if not more crucial, problems. California cotton gins in the San Joaquin Valley are in a serious non-attainment area for PM10; therefore, they are being forced to reduce their PM10 emission. In 2004-2005, the corresponding air district for these cotton gins was in the process of developing new rules to reduce cotton gin PM10 emissions. The air district was proposing a rule that would require all cotton gins within the district to replace their current abatement devices (typically 1D-3D cyclones) with baffle-type pre-separators followed by 1D-2D cyclones on all exhausts. The air district's decision was based on limited research information. The general consensus for the ginning and scientific community was that implementing these abatement technology changes would result in significant economic impacts on the affected cotton gins without a significant reduction, or possibly even an increase, in PM10 emissions. If the gins were to make these changes and the PM10 emission was not reduced to the level required by the air district, then the gins would be required to implement additional abatement controls specified by the air district. This is a prime example of the current issues facing agricultural industries throughout the United States. Air districts within non-attainment areas are feeling pressure to reduce PM emissions, and are passing the pressure on to agriculture by implanting rules and regulations. States or air districts that are non-attainment must develop a state implementation plan (SIP). This process requires emission factor estimates for all the various sources within the specified region. However, in many cases research has not been conducted to determine these emission factors; therefore, very conservative estimates are assumed for the various operations within the air-shed. Further, if an operation (such as tillage or harvesting) were required to implement best management practices to reduce PM10 emissions, the emission factors associated with these practices would have to be determined. By holding rural sources to a substantially higher standard than urban sources, federal and state regulatory agencies are essentially placing unjust economic burdens on rural sources, including agricultural industries. These economic burdens include, but are not limited to, costs associated with implementing additional abatement devices, regulatory fees and/or fines, and regulatory agency demands for additional source sampling. 2.List the milestones (indicators of progress) from your Project Plan. (Milestones originally developed for Project No. 6208-21410-005-00D, Harvesting and ginning processes to enhance the profitability of stripper cotton). FY 2005: Model particle conveyance and pollution abatement devices with computational fluid dynamics (CFD). Develop the theoretical errors associated with stack samplers. Develop samplers and procedures for determining PM10 and PM2.5 emission factors at cotton gins. Determine foreign matter composition from gin processes on collection efficiencies for common cotton gin abatement devices. Develop CFD models of baffle-type pre-separators. Develop testing procedures for evaluating effects of inlet airflow rate and trash loading on cyclone efficiency. FY2006: Validate CFD model for particle conveyance. Develop procedures to validate the theoretical errors in stack samplers. Conduct initial tests in laboratory of new samplers and procedures for determining PM10 and PM2.5 emission factors. Determine the effect of material composition from gin processes on collection efficiencies for common cotton gin abatement devices. Construct pre-separators utilizing data developed from CFD models. Conduct initial tests evaluating effects of inlet airflow rate and trash loading on cyclone efficiency. FY2007: Continue validation of CFD model for particle conveyance and pollution abatement devices. Conduct tests to determine the actual errors associated with stack samplers. Continue laboratory testing of samplers and procedures for determining PM10 and PM2.5 emission factors. Continue evaluating the effect of material composition from gin processes on collection efficiencies for common cotton gin abatement devices. Continue tests evaluating effects of inlet airflow rate and trash loading on cyclone efficiency. FY2008: Complete stack sampler tests and estimate the economic impacts of the errors for cotton gins. Conduct testing of samplers and procedures for determining PM10 and PM2.5 emission factors in commercial cotton gin. Determine the effect of material composition from gin processes on collection efficiencies for cotton gin abatement devices. Conduct optimization testing of baffle-type pre-separators. Complete tests and evaluate results of inlet airflow rate and trash loading on cyclone efficiency. FY2009: Laboratory and field evaluations of CFD model for particle conveyance and pollution abatement devices. Complete economic analysis of stack errors on cotton gins. Finish field testing of samplers and procedures for determining PM10 and PM2.5 emission factors. Conduct field tests of baffle-type pre-separators in commercial cotton gins. 4a.What was the single most significant accomplishment this past year? Experimental versus theoretical PM sampler errors: Research focused on determining the errors associated with particulate matter (PM) samplers, both ambient air and stack samplers. Based on the actual data collected from the PM10 ambient air samplers, the true PM10 concentration was experimentally determined to be roughly 51% of the PM10 concentration determined with the PM10 ambient air sampler. In order for the experimental data to vary so far beyond the theoretical data, the PM10 sampler's cutpoint and slope must be varying beyond EPA's defined performance criteria. Results from this preliminary research indicate that the theoretical errors associated with EPA-approved PM samplers is extremely conservative. This work was conducted at the Cotton Production and Processing Research Unit at Lubbock, TX, in cooperation with the Center for Agricultural Air Quality Engineering and Science at Texas A&M University. 4b.List other significant accomplishments, if any. Development of a new, low-volume, total suspended particulate matter sampler head: A new aerosol sampler for ambient air utilizes low-volume (16.7 lpm) sampling techniques and unique design features. The device inhibits particles greater than 100 microns from being sampled, reducing contamination of large materials on the filter media, and also includes a unique design with filter cartridge to hold a standard 47-mm diameter filter that allows easier and quicker filter changes, reducing the likelihood of filter contamination. The complete unit is compact, minimizing the length of piping through which the air must flow and minimizing errors due to deposition of particulate on the pipe instead of the filter media. Currently, researchers, air pollution regulatory agencies, and commercial contractors use low-volume PM10 or PM2.5 samplers to determine the particulate matter emission being emitted from specific operations or being emitted within a region. Recent research has indicated that significant concentration measurement errors occur when using these PM10 and/or PM2.5 samplers in an agricultural environment. This invention, currently under review by Texas A&M Universities Patent Office, reduces those errors and provides an accurate concentration measurement. The sampler was developed cooperatively by the USDA Cotton Production and Processing Research Unit at Lubbock, TX, the USDA Southwestern Cotton Ginning Research Laboratory at Mesilla Park, NM, and the Center for Agricultural Air Quality Engineering and Science at Texas A&M University. Completion of the ASAE cotton gin emission factor standard: A standard was developed that defines the operations of a cotton gin with engineering data that can be used by both consulting and permit engineers so cotton gins are appropriately regulated. Included in the scope of this standard are standardized procedures for calculating emission factors from emission concentrations and hourly and seasonal emission rates from given (permitted) emission factors. Emission factors, specified in a permit, represent the allowable mass of PM that can be emitted per bale of cotton processed at a gin for a specified air pollution abatement system while maintaining compliance with the permit. Emission factors may be dependent upon a combination of factors, including the number of process streams and abatement devices used. The appropriate use of emission factors in calculating cotton gin emission rates and inventories is demonstrated in this standard. This standard was completed and approved for publication in February of 2005. Agriculture engineers from the cotton industry, including state, federal, and private organizations, helped develop this standard under leadership of engineers from the USDA Cotton Production and Processing Research Unit at Lubbock, TX. Theoretical errors associated with the EPA-approved Method 201a stack samplers: Theoretical analyses of the errors associated with EPA's Method 201a samplers were conducted. EPA's performance criteria for the Method 201a samplers provide tolerances for acceptable sampler cut points and slopes. These defined tolerances are much broader than those specified for the PM10 ambient air samplers, which result in a larger PM10 concentration uncertainty associated with the Method 201a sampler as compared to the EPA-approved PM10 ambient air samplers. Based on the particle size distribution (PSD) and sampler performance characteristics, 96% of PM emitted from a simulated power plant is less than 10 microns and 87% of the total suspended particulate (TSP) is captured by the PM10 sampler. The true PM10 emitted from the agricultural operation was found to be over-sampled by 346%, indicating the two operations are not equally regulated. Although an over-sampling rate of 346% appears extreme, experimental tests conducted on EPA approved PM10 ambient air samplers have produced over-sampling rates in excess of the theoretical rates, indicating that the simulated data is relatively conservative. This work was conducted at the USDA Cotton Production and Processing Research Unit at Lubbock, TX, in cooperation with the Center for Agricultural Air Quality Engineering and Science at Texas A&M University. Evaluation of the baffle-type pre-separator: An abatement system consisting of a baffle-type pre-separator followed by an over-sized 1D-3D cyclone was evaluated over a range of pre-separator inlet air velocities, gin waste loading rates, and baffle locations. None of the treatments significantly affected the oversized cyclone or overall collection efficiency. Loading rate significantly affected pre-separator efficiency, but not to the extent of inlet velocity. The baffle-type pre-separator performed well at reducing the course material loading rate entering the cyclone. Utilization of a baffle-type pre-separator in an abatement system will reduce the loading on the cyclone and provide a more efficient and environmental friendly processing system. This work was conducted at the USDA Cotton Production and Processing Research Unit at Lubbock, TX, in cooperation with the Center for Agricultural Air Quality Engineering and Science at Texas A&M University. Accounting for fugitive emissions when conducting property line sampling: When dispersion modeling or property line sampling is used to determine whether or not a cotton gin is in compliance with its allowable emission rate as defined in the gins operating permit, it is important to recognize that there are two sources of PM:. 1)the gins' exhaust systems and. 2)fugitive emissions from the gin yard and/or roads within the facilities property boundary. Fugitive emissions are not generally included in a facilities permit unless the facility is considered a major source. Currently, there are no cotton gins that meet the Title V major source threshold, so a gin's fugitive emissions should not be included in dispersion modeling runs, and property line sampling concentrations should be adjusted to remove the effects of fugitive emissions. This research explored the potential impacts of including fugitive emissions in determining whether or not a gin is in compliance with its operating permit. The EPA-approved Gaussian-based model, Industrial Source Complex Short Term Version 3 (ISCST3), was used in the simulations. Results from the simulations indicated that the average contribution of the uncontrolled gin yard and road emissions could be as high as 35%. Although these simulations are based on EPA AP-42 emission factors and not actual field data, the simulations demonstrate the importance of including only relevant emissions in modeling and knowing the sources that can impact property line sampling concentrations and appropriately accounting for these non-regulated sources of PM. This work was conducted at the USDA Cotton Production and Processing Research Unit at Lubbock, TX, in cooperation with the Center for Agricultural Air Quality Engineering and Science at Texas A&M University. 4c.List any significant activities that support special target populations. None. 5.Describe the major accomplishments over the life of the project, including their predicted or actual impact. The need to reduce emissions from cotton gins has led to improved designs for separating and capturing dust. Design modifications in the inlet and outlet of cyclones have led to lowering of PM10 emissions between 8% and 9% (NP 203, STP 5.2.3). Improved pre-separators have shown the ability to significantly reduce large foreign matter, allowing cyclones to more efficiently remove fine dust. 6.What science and/or technologies have been transferred and to whom? When is the science and/or technology likely to become available to the end-user (industry, farmer, other scientists)? What are the constraints, if known, to the adoption and durability of the technology products? Currently, a patent application has been submitted through Texas A&M University Patent Office for a low-volume, total suspended particulate matter sampler head that was cooperatively developed by the USDA Cotton Production and Processing Research Unit at Lubbock, TX, the USDA Southwestern Cotton Ginning Research Laboratory at Mesilla Park, NM, and the Center for Agricultural Air Quality Engineering and Science at Texas A&M University. The sampler will be integrated into the present sampling system and made commercially available upon receiving a patent. 7.List your most important publications in the popular press and presentations to organizations and articles written about your work. (NOTE: List your peer reviewed publications below). Smith, Darrell. 2004. A dust storm brewing. AgWeb.com. November 3, 2004. A federal air quality researcher said agriculture may be shouldering too much of the blame for dust borne pollution. North County Times – The Californian. November 15, 2004. Ag dust more accurately measured. Poultry Times. October 25, 2004. More precise way to gauge ag dust found. Western Farm Press. October 16, 2004. Review Publications Buser, M.D., Whitelock, D.P., Holt, G.A., Armijo, C.B., Wang, L. 2005. Preliminary evaluation of the baffle-type pre-separator in terms of baffle location, critical air velocity, and loading rate. In: Proceedings of the Beltwide Cotton Conference, January 4-7, 2005, New Orleans, Louisiana. p. 469-485. 2005 CDROM. Baker, K.D., Hughs, S.E., Buser, M. 2004. Comparison of source testing and boundary line testing for emissions from a cotton gin. American Society of Agricultural Engineers. Paper No. 044011. Capareda, S.C., Buser, M.D., Whitelock, D.P., Green, J.K., Parnell, Jr., C.B., Shaw, B.W., Wanjura, J.D. 2005. Particle size distribution analysis of cotton dust and its impact on PM10 concentration measurements. In: Proceedings of the Beltwide Cotton Conference, January 4-7, 2005, New Orleans, Louisiana. p. 631-642. 2005 CDROM. Goodrich, L. Barry, Buser, Michael. 2005. Particulate matter sampler errors due to the interaction of particle size and sampler performance characteristics. In: Proceedings of the California Plant and Soil Conference, California Chapter of the American Society of Agronomy, February 1-2, 2005, Modesto, CA. p. 38-45. Hamm, L.B., Buser, M.D., Capareda, S.C., Wanjura, J.D., Parnell, Jr., C.B., Shaw, B.W. 2005. Cotton gin yard and road dust emissions and the resulting effects on downwind samplers. In: Proceedings of the Beltwide Cotton Conference, January 4-7, 2005, New Orleans, Louisiana. p. 602-613. 2005 CDROM. Hughs, S.E., Armijo, C.B., Whitelock, D.P., Buser, M.D. 2005. Particulate concentration measurement at a New Mexico cotton gin. In: Proceedings of the Beltwide Cotton Conferences, January 4-7, 2005, New Orleans, Louisiana. p. 553-559. 2005 CDROM. Shaw, B.W., Lacey, R.E., Capareda, S., Buser, M.B., Parnell, Jr., C.B., Wanjura, J., Wang, L., Faulkner, W.B. 2004. Application of the National Ambient Air Quality Standards (NAAQS) in urban versus rural environments. American Society of Agricultural Engineers. Paper No. 044016. Wang, L., Wanjura, J.D., Faulkner, B., Parnell, Jr., C.B., Shaw, B.W., Lacey, R.E., Capareda, S.C., Buser, M.D. 2004. Study of "baffle type pre-separator plus cyclone" abatement systems for cotton gins. American Society of Agricultural Engineers. Paper No. 044017. Wang, L., Parnell, C.B., Shaw, B.W., Lacey, R.E., Buser, M.D., Goodrich, L.B., Capareda, S.C. 2005. Correcting PM10 over-sampling problems for agricultural particulate matter emissions: preliminary study. Transactions of the ASAE. 48(2):749-755.