AQ_F_0400044_20141029_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: 11/03/2014
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 10/29/2014
Inspector's Name Mike Thomas
Inspector's Signature: Operating Status Operating
Compliance Code Compliance-inspection
,Q N Action Code FCE -
Date of Signature: On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2011 20.31 --- 6.94 ---
2006 23.98 --- --- --- --- 8.19 ---
Highest HAP Emitted(in ounds
Five Year Violation History:None
Date Letter Tyne Rule Violated Violation Resolution Date
r
ack Tests since last FCE:None
Test Results Test Method(s) Source(s)Tested
1) Location:
Piedmont Cotton is located at 195 Cotton Street, in Polkton,NC,Anson County.

Directions
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—%mile until Cotton Street.Turn right, and facility entrance will be on left
hand side in—.2 of a mile.Turn left onto dirt drive and warehouse office entrance will be— 100 yards to the
left.
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.
2) Facility and Process 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 21 November 2013.
Piedmont Cotton Inc is a cotton ginning operation which produces raw cotton for industrial use.
This existing facility has documented that the manufacturer's rated capacity of this gin is 30 bales per
hour and is based on 3 gin stands,each with a capacity of 10 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.
a) Throughputs for 2013
Employees: 9(same in 2012)
Hours: 8:OOAM—8:00 PM,Mon—Fridays
Bale Production in 2012: 17,906
Projected Bales for 2013: —7,000(low production year due to weather issues)
Bale Production in 2013: 6,290
Project Bales for 2014: 10,000
b) Permitted Sources
Emission Emission Source Control Control System
Source ID Description System 1D Description
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. 15%
3) Inspection Conference:
On 29 October 2014,I Mike Thomas of FRO DAQ conducted a compliance evaluation inspection of the
Piedmont Cotton hic.facility.I met with Mr.Robert Williamson Jr.,Manager at 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 the 1 October 2014. The new season baseline was performed
by Rafe Dixon 9 September 2014. Pressure checks occur monthly. The facility has operated steadily
since the season began. This cotton gin facility is rated at 90 bales per hour(3 gin stands, 30 bales/hr
each), Emissions are controlled by cyclones on the lint cleaners and battery condensers.
_ c) The daily inspection is done primarily by Mr. Williamson and the log entries showed his initials
(RW). Entries for this year's inspections were more detailed in cases where maintenance or other
activities took place. Overall record keeping looked good.
d) There have been no new system designs or equipment changes prior to this gin season; only routine
maintenance was done.
4) 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 15%.
We then inspected the waste bin which appeared to be functioning well with only a small amount of
_ accumulation around it. Mr.Williamson said that they fill the waste truck twice a day.The waste is hauled off by
local farmers.Mr. Williamson then led me on a tour of 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.
5) Regulatory Review:
A.3 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 15%opacity. The dump area
cyclone was operating at 15%opacity.
A.6 2D .0540 FUGITIVE DUST CONTROL REQUIREMENT-The Permittee shall not cause or allow
fugitive dust emissions to cause or contribute to substantive complaints or excess visible emissions beyond the
property boundary.
Appeared to be in Compliance—No complaints had been received. Excessive dust/lint was not observed on
surrounding vegetation or on the facility grounds.
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 Compliance—No objectionable odors were detected at the facility's boundary or while on
site.
A.8 2D .0542 CONTROL OFPARTICULATE 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 Compliance—Mr. Williamson had all the pertinent records as required by the air permit.
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 2 10 MPH speed limit
signs,haul trucks are covered, initial baseline study was done on 9 September 2014 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.
CY2012 Annual Report was received at FRO on 12 March 2014 and appeared in compliance because 6,290
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.
A.9 2D.0310 COTTON UNREOUIREMENT—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.
A.1020.0806 LIMITATION TOA VOID 15ANCAC20.OS0I(PROHIBITORYSMALL)—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
18,000 cotton bales were ginned in CY2012 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.
6) Compliance History
None the past 5 years.
7) Comments and Compliance Statement
Mr.Williamson continues to effectively manage the cotton waste around the facility.
Piedmont Cotton, Inc. appeared to be in compliance on 29 October 2014.
Pink Sheet: no comments
/mst