AQ_F_0400044_20171114_CMPL_CAV-Rpt

-NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY Piedmont Cotton Inc
_ NC Facility ID 0400044
Inspection Report County/FIPS:Anson/007
Date: 12/8/2017
Facility Data Permit Data
Piedmont Cotton Inc Permit n/a
195 Cotton Street Issued n/a
Polkton,NC 28135 Expires n/a
j Lat: 34d 59.7360m Long: 80d 12.4970m Classification Registered
SIC: 0724/Cotton Ginning Permit Status Inactive
NAILS: 115111/Cotton Ginning Current Permit Application(s)None
j Contact Data Program Applicability
yFacility Contact Authorized Contact Technical.Contact SIP
Robert Williamson,Jr. Robert Williamson, Sr. Robert Williamson,Jr.
Vice President President Vice President
(704)272=7580 [phone] [phone]
Compliance Data '
Comments:
Inspection Date 11/14/2017
Inspector's Name Mike Thomas
Inspector's ignature: Operating Status Operating
Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: On-Site Inspection Result Compliance
l2 -f3—/71
Total Actual emissions in TONS/YEAR:
f TSP S02 NOX VOC CO . PM10 *HAP -
2011 20.31 --- --- --- --- 6.94 ---
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2006 23.98 --- --- --- --- 8.19 ---
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P *Highest HAP Emitted inpounds)
Five Year Violation History:None
Date Letter Type Rule Violated Violation Resolution Date
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Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested
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1) Location/Directions:
f Piedmont Cotton is located at 195 Cotton Street, in Polkton,Anson County. In Wadesboro,continue
f on HWY 74W-5 miles until Poplar Hill Church Road(BJ's Diner will be on the left hand corner).
Turn Jeft and go-1/2 mile to Cotton Street. Turn right,and facility entrance will be on right hand
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side in—.2 of a mile.Turn left onto dirt drive and the warehouse office entrance will be— 100 yards
to the left.
2) Safety Considerations:
Standard DAQ safety equipment.Watch for trucks entering and leaving, as well as cotton module
trucks coming into and out of warehouse. Be aware of all operating gin equipment.
3) Facility Process and Description:
Piedmont Cotton,Inc. is a cotton ginning operation that produces raw cotton for industrial use. The
facility requested registration under 15A NCAC 02Q .0102"Activities Exempted from Permit
Requirements"and DAQ issued the registration on 26 April 2017.
This facility operates three gin stands, each with a maximum rated capacity of 12 to 15 bales per
hour fora facility maximum rated capacity of 36 to 45 bales per hour. The facility combusts liquid
propane gas(LPG)to dry the cotton. Seasonal dry/wet weather condition determines combustion
usage which respectively ranges from 1.1 to 1.5 gallons of fuel per bale of ginned cotton. .At present,
the facility operates seven parallel cyclones on each gin stand and one at the waste area. Each of
these cyclones are 113-31). Proper static pressure readings and visible emission observations are used
to maintain compliance with 2D.0542 regulations.
4) ermrtted Sources
Emission Emission Source Control Control System
Source ID Description System ID Descri tion
CG-1 Emission sources and air filtration system(s) CS-1 Cyclones(lD-3D and 2D-2D
utilized in the cotton ginning process, cyclones typical per 2D.0542)
(Standard Industrial Classification Code
(SIC)0724) [maximum rated gin stand
capacity greater than or equal to 20 bales
per hour regardless of the number of gin
stands and/or modified or new facilities
constructed after July 1,2002]
Observed Operating V.E. 10%
5) Inspection Conference:
On 14 November 2017,1 Mike Thomas and Steve Allen,both of FRO DAQ,conducted a
compliance inspection of the Piedmont Cotton Inc., facility. We met with Mr.Robert Williamson
Jr.,manager of the facility. We discussed the following:
a) Mr. Williamson verified that the FACFINDER information was correct and current.
b) Piedmont Cotton Inc.,began ginning on 19 October 2011. The new season baseline was
performed by Mr.Rafe Dixon on 12 October 2017. The facility has operated steadily since the
season began. The production rate of this gin is limited to 30 bales an hour as that is the
maximum rate of the press,however, according to Mr.Williamson 27 bales per hour is what he
typically averages. All three gin stands feed the one baler at approximately the same rate,
simultaneously.
c) I examined the logbook that Mr. Williamson maintains,which is kept readily available in the
office in the ginning building. Daily entries for this season began on 19 October 2017 when the
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gin started operating this season. Mr. Williamson conducts the daily inspections and air flow
checks himself. The logbook contained entries for the previous seasons as well.
The monthly inspection section of the logbook contained this season's baseline information.
The baseline study was conducted on 12 October 2017 by an outside contractor,Mr. Rafe
Dixon. Values for inlet velocity, static pressure, and pressure drop were documented in the .
report provided by Mr.Dixon. Entries for monthly inspections and flow and pressure readings
1 were also documented. Mr.Williamson conducts the monthly inspections. No documented
7 entries were out of the indicated ranges,therefore no corrective actions were required or
documented.
d) Mr. Williamson informed me that the facility had found ways to eliminate most of their waste
products. They had been baling their trash from the ginning process to be sold to feed livestock.
The facility now has buyers for the seed recovered during ginning and for the plastic that the
round bales are encased in.
e) Production:
Year Number of Bales
2016 11,200
2015 10,876
_ 2014 12,901
2013 6,290
6) Inspection Summary:
Mr.Williamson led us on a tour of the facility starting with the cyclones behind the gin building.
The cyclones appeared to be in good shape. All of the external duct work appeared to be in good
shape as well. V.E.at the cyclones was 10%. I observed no problems. The area around the
cyclones was very clean.
I observed the waste:baling system. The baler is located below the cyclones. Waste drops from_
bottom of the cyclones into a bin and is conveyed into the baler: The baler compresses the waste
into a dense block roughly the size of a bale of hay. Mr. Williams still maintains the old waste bin
and can use it to stock pile material in the event that the baler breaks down.
We then toured the inside of the ginning building. All three of the gin stands were operating during
the inspection. The inside of the facility was very clean. I observed no problems.
7) Applicable Air Quality Regulations:
a) A.2 Record Keeping: (15A NCAC 2D .0202)-The Registrant shall maintain records on site to
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establish that facility-wide annual air pollutant emissions remain below the 25 ton per year threshold
level listed above. Records(in written or electronic format)shall be maintained for a minimum of
E two years and made available to DAQ personnel upon request.
APPEARED TO BE IN COMPLIANCE: Facility keeps track of total number of bales ginned
during the ginning season and reports the final total to the Division of Air Quality annually.
b) Notification Requirements: (15A NCAC 2D .0202)-The Registrant shall notify DAQ as soon as
possible of the following occurrences: process modification,name/ownership/location change, and
or increase in emissions.

APPEARED TO BE IN COMPLIANCE: According to Mr. Williamson their have been no
changes to the facility's operations,contact information, or emissions that would require !
notification.
c) Excess Emissions Notification Requirements: (15A NCAC 2D .0535)-The Registrant must report j
excess emissions of any regulated pollutant lasting more than four(4)hours, and that result from a
malfunction,to the Division of Air Quality by 9 am of the next working day.
APPEARED TO BE IN COMPLIANCE: Mr.Williamson stated that there have been no
exceedances of emissions that would have required reporting.
d) Fugitive Dust Control Requirement: (15A NCAC 2D .0540)-The Registrant shall not cause or 1
allow fugitive dust emissions to cause or contribute to substantive complaints or excess visible
emissions beyond the property boundary.
APPEARED TO BE IN COMPLIANCE: We observed no issues with fugitive at the facility or '
beyond the boundaries of the property. Mr.Williamson stated that he was unaware of any dust
complaints at the facility.
e) Control of Particulate Emissions from Cotton Ginning Operations: (15A NCAC 2D .0542)-For gins
rated at> 20 bales/hour,the Permittee shall comply with emission control requirements,rain caps,
operation and maintenance,fugitive emissions(from trash composter,gin yard,traffic areas, and
transport of trash material),monitoring(includes.baseline-studies. static.pressure checks,and daily 7
inspections),recordkeeping,reporting,record retention, and alternative control measures.
APPEARED TO BE IN COMPLIANCE:Mr.Williamson had all the pertinent records as required
by the rule. The facility appears compliant with the following: uses 1D-3D cyclones,rain caps are
removed, auger and dump area has wet suppression,gin yard and process areas are cleaned daily,
there are two 10 MPH speed limit signs,haul trucks are covered, initial baseline study was done on
12 October 2017 by Mr.Raif Dixon, static pressure checks are performed every 30 days, daily
inspections for structural integrity are performed and documented, and record retention requirements
were being followed.
CY2016 Annual Report was received'at FRO on 27 March 2017 and appeared in compliance
because 11,201 bales were ginned,well below the limit of 167,000 bales per 12-month period. The
facility also submitted a close.of year inspection sheet stating that no repairs would be needed before
the next season.
f) A.5 15A NCAC 2D .0521 VISIBLE EMISSIONS CONTROL REQUIREMENT—Visible
emissions from the emission sources shall not exceed 20%opacity.
APPEARED IN COMPLIANCE—V.E.was 10%during this inspection.
8) 112R Status
This facility does not store chemical compounds that require a written risk management plan under
the Clean Air Act, Section 112R.
9) Non-compliance History Since 2010:
None.
10) Comments and Compliance Statement:
Piedmont Cotton,Inc. appeared to be in compliance on 14 November 2017.
Pink Sheet: no comments
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