AQ_F_0400044_20151118_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY Piedmont Cotton Inc
NC Facility ID 0400044
Inspection Report County/FIPS:Anson/007
Date: 11/20/2015
Facility Data Permit Data
Piedmont Cotton Inc Permit 08152/G04
195 Cotton Street Issued 7/16/2012
Polkton,NC 28135 Expires 6/30/2017
Lat:34d 59.7360m Long: 80d 12.4970m Classification Small
SIC: 0724/Cotton Ginning Permit Status Active
NAICS: 115111/Cotton Ginning Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP
Robert Williamson,Jr. Robert Williamson, Sr. Robert Williamson,Jr.
Manager President Manager
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 11/18/2015
Inspector's Name Mike Thomas
Inspector's Signature: Operating Status Operating
Compliance Code Compliance-inspection
Action Code FCE
Date off Signature: On-Site Inspection Result Compliance
f/- 2a-l5
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2011 20.31 --- 6.94 ---
2006 23.98 --- --- --- --- 8.19 ---
Flighest HAP Emitted(in ounds)
Five Year Violation History:None
Date Letter Type Rule Violated Violation Resolution Date
Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested
1) Location/Directions:
Piedmont Cotton is located at 195 Cotton Street,in Polkton,Anson County. In Wadesboro, continue
on HWY 74W—5 miles until Poplar Hill Church Road(BJ's Diner will be on the left hand corner).
Turn left and go—'/2 mile to Cotton Street. Turn right,and facility entrance will be on right hand

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. This
facility is permitted under Air Permit No. 08152G04,effective from 16 July 2012 until 30 June
2017.Mike Thomas conducted the last compliance inspection on 29 October 2014.
This existing facility has documented that the manufacturer's rated capacity of this gin is 45 bales
per hour and is based on 3 gin stands,each with a capacity of 15 bales per hour. Therefore the gin
will be given the general prohibitory small permit for cotton gin facilities with a rated capacity>20
bales per hour.
4) Permitted Sources:
-- --—.. _ ---- - ----— - - ------- ._
Emission Emission Source Control Control System
Source ID Description System ID i� Description
CG 1 Emission sources and air filtration system(s) C CS-1 j Cyclones(1D-31)and 2D-2D
utilized in the cotton ginning process, 1 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] j
Observed Operating V.E. 5% j
5) Inspection Conference:
On 18 November 2015,I Mike Thomas;of FRO DAQ, conducted a compliance inspection of the
Piedmont Cotton Inc,, facility. I 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 9 October 2015. The new season baseline was
performed by Mr.Rafe Dixon on 15 September 2015. 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. The gin stands are actually rated for higher capacity.
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 9 October 2015 when the -
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 15 September 2015 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
were also documented. No documented entries were out of the indicated range,therefore no
corrective actions were required or documented.
d) Production data for 2014:
Employees: 9 (same in 2013)
Hours: 8:OOAM—8:00 PM,Mon—Fridays
Bale Production in 2012: 17,906
Bale Production in 2013: 6,290
Bale Production in 2014: 12,901
Projected Bale Production 2015: 10,000
e) According to Mr. Williamson,there have been no changes made to the ginning equipment since
the last inspection. He did inform me that the facility is using a new baling system for their
waste material. Some of the bales are sold to local farmers and some are exported to be turned
into pellet fuel for cooking etc.
6) Inspection Summary:
Mr.Williamson led me 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 5%. I observed no problems.
Mr.Williamson showed me the new waste baling system. The baler is located below the cyclones.
Waste drops from the 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. MT. 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. Mr. Williamson explained the flow of cotton through the facility.The inside of the
facility was very clean. I observed no problems.
7) Stipulation Review:
a) A.22Q .0304PERMITRENEWALandEMISSIONINVENTORYREQUIREMENT—
Entire facility subject. Submit permit renewal application and EI at least 90 days prior to
permit expiration.
APPEARED TO BE IN COMPLIANCE—The most recent EI and Permit Renewal were due
on 2 May 2012. The facility submitted their EI on 23 April 2012 and the permit renewal
application was received on the same date.
b) A.4 2D .0521 VISIBLE EMISSIONS CONTROL REQUIREMENTS—Visible emissions
from the emission sources,manufactured after July 1, 1971,shall not be more than 20 percent
opacity when averaged over a six-minute period.
APPEARED TO BE IN COMPLIANCE—The gin stand cyclones were operating at 5%
opacity. Each piece of equipment was properly identified and the manufacturing data plates all
indicated that they were built after 1 July 1971.
c) A.5 2D .0535 NOTIFICATION REQUIREMENT- The facility is required to notify DAQ if
excess emissions occur for more than a 4-hour period caused by a breakdown or other abnormal
condition.

APPEARED TO BE IN COMPLIANCE—According to Mr. Williamson,the facility has had
no exceedances,breakdowns, or abnormal conditions requiring notification.
d) A.6 2D .0540 FUGITIVE D UST CONTROL REQUIREMENT—The Permittee shall not
cause or allow fugitive dust emissions to contribute to complaints or excessive visible
emissions beyond the property boundary.
APPEARED TO BE IN COMPLLANCE —The driveways for this facility are all gravel but
due to recent rains I could not make a determination of dust coming from the driveways. The
one truck that I observed leaving the facility was covered. I did not observe any evidence of
cotton fibers on trees or surrounding vegetation. Mr. Williamson stated that he has had no
complaints regarding dust.
e) A.7 2D .1806 CONTROL AND PROHIBITION OF ODOROUS EMISSIONS-The
Permittee shall not allow odorous emissions beyond the facility's boundary.
APPEARED TO BE IN COMPLLANCE—No objectionable odors were detected at the
facility's boundary or while on site. Mr. Williamson stated that he had not received any
complaints regarding odor.
f) A.8 2D .0542 CONTROL OF PARTICULATE EMISSIONS FROM COTTON GINNING
OPERATIONS—For gins rated at> 20 bales/hour,the Permittee shall comply with permitted
conditions, including emission control requirement,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 inspections),
recordkeeping, reporting,record retention,and alternative control measures.
APPEARED TO BE IN COMPLLANCE—Mr. Williamson had all the pertinent records as
required by the air permit. The facility appears compliant with the following: uses 1D-31)
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 15 September 2015 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.
CY2014 Annual Report was received at FRO on 25 February 2015 and appeared in compliance
because 12,901 bales were produced,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.
g) A.9 2D .0310 COTTON GIN REQUIREMENT—Facility will not operate any emission
sources other than those that are permitted.
APPEARED TO BE IN COMPLIANCE—Facility is only operating permitted emission
sources.
h) A.10 2Q .0806 LIMITATION TOA VOID 15A NCAC 2Q .0501(PROMBITORY SMALL)
—Facility-wide potential PM10 shall be less than 100 tons per consecutive 12 month period and
gin production less than 167,000 bales of cotton per consecutive 12-month period; annual
report shall contain number of bales produced,with records to be maintained documenting
such.
APPEARED TO BE IN COMPLIANCE—Latest permit review showed compliance; annual
report stated that 12,901 cotton bales were ginned in CY2014 which is well below the limit of
167,000 bales per 12-month period,with facility having documentation showing compliance
with this limitation during this inspection.

8) 112R Status
This facility neither uses nor stores 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:
The facility was the cleanest outside that I have observed since I began inspecting it. I believe a
significant portion of that is due to the new waste baling system.
Piedmont Cotton, Inc. appeared to be in compliance on 18 November 2015.
Pink Sheet: no comments
/mst