Engineering analysis of the air pollution regulatory process impacts on the agricultural industry



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Texas A&M University


The EPA press release dated February 23, 2004 states that the three Buckeye Egg Farm facilities had the potential to emit more than a combined total of 1850 tons per year of particulate matter (PM). This number was based on flowrate calculations that were three times higher than those measured as well as a failure to include particle size distributions in the emissions calculations. The annual PM emission for each facility was approximately 35 tons per year. The EPA was unjustified in requiring Buckeye Egg Farm to obtain Title V and PSD permits as the facilities could not have met the thresholds for these permits. Engineers need to be concerned with correctly measuring and calculating emission rates in order to enforce the current regulations. Consistency among regulators and regulations includes using the correct emission factors for regulatory permitting purposes. EPA has adopted AERMOD as the preferred dispersion model for regulatory use on the premise that it more accurately models the dispersion of pollutants near the surface of the Earth than ISCST3; therefore, it is inappropriate to use the same emission factor in both ISCST3 and AERMOD in an effort to equitably regulate PM sources. For cattle feedlots in Texas, the ISCST3 emission factor is 7 kg/1000 hd-day (16 lb/1000 hd-day) while the AERMOD emission factor is 5 kg/1000 hd-day (11 lb/1000 he-day). The EPA is considering implementing a crustal exclusion for the PM emitted by agricultural sources. Over the next five years, it will be critical to determine a definition of crustal particulate matter that researchers and regulators can agree upon. It will also be necessary to develop a standard procedure to determine the crustal mass fraction of particulate matter downwind from a source to use in the regulatory process. It is important to develop a procedure to determine the particulate matter mass fraction of crustal downwind from a source before the crustal exclusion can be implemented to ensure that the exclusion is being used correctly and consistently among all regulators. According to my findings, the mass fraction of crustal from cattle feedlot PM emissions in the Texas High Plains region is 52%.