AQ_F_0400044_20131121_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: 12/04/2013
Facility Data Permit Data
Piedmont Cotton Inc Permit 08152/G04
195 Cotton Street Issued 7/16/2012
Polk-ton,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 11/21/2013
Inspector's Name Mike Thomas
Inspector's ig/nature: Operating Status Operating
Rya Compliance Code Compliance - inspection
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 Type Rule Violated Violation Resolution Date
Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s) Tested

1) Location:
Piedmont Cotton is located at 195 Cotton Street, in Polkton,NC,Anson County.
Directions
From FRO,take Hwy 401 South to Wagram.Turn right onto Old Wire Road(Hwy144)and go— 11 %miles
to Laurel Hill. Turn right at Hwy 74, go—35 miles west through Wadesboro, and continue—5 miles until
Poplar Hill Church Road(BYs Diner will be on the left hand corner). Turn left and go— %2 mile until Cotton
Street.Turn right,and facility entrance will be on left hand side in—.2 of a mile.Tom 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. Robert
Hayden conducted the last compliance inspection on 13 November 2012.
Module trucks and trailers transport cotton from the field to the gin.A pneumatic system removes the cotton
from the trailers, and either a pneumatic system or a module feeder removes the cotton from modules.A
combination conveyer and pneumatic system conveys the cotton to a separator and feed control unit.Prior to
this first separator point,some gins use a stone and green boll trap for preliminary trash removal.The screen
assembly in the separator allows air to escape but collects the cotton and allows it to fall into the feed control
unit.The conveying air flows from the separator to a cyclone system,where it is cleaned and discharged to
the atmosphere.
There are 4 main systems included in the ginning of cotton:a)Seed cotton cleaning-involves drying to reduce
lint cotton moisture content to 5 to 8%, one cleaning to remove fine dirt particles and a second cleaning to
extract larger debris b)Overflow- if the flow of cotton exceeds the limit of the extractor/feeder systems,the
excess cotton flows into the overflow hopper and is returned back to the conveyor distributor c) Ginning and
lint handling-the cotton enters the gin stand, goes thru a set of"saws"that strip off hulls and sticks, and then
enters a roll box,where fibers are separated from the seeds(which fall to the bottom of the gin stand for
subsequent pneumatic removal to a storage area).Cotton lint is then conveyed pneumatically to the lint cleaning
system(normally consisting of 2 cleaners)for final cleaning and combing d)Battery condenser and baling-
the lint cotton is pneumatically transported to a battery condenser,which separates it from the conveying
air. Cotton is then formed into batts and fed into a baling press,which finally compresses the cotton into
uniform bales,which are either sent directly to the customer or to storage.
a) Throughputs for 2013
Employees: 9 (same in 2011)
Hours: 8:OOAM—8:00 PM,Mon—Fridays (only on weekends in 2009)
Bale Production in 2012: 17,906
Projected Bales for 2013: —7,000(low production year due to weather issues)

b) Permitted Sources
Emission Emission Source Control Control System
ISource ID '� Description System ID Description
CG-1 Emission sources and air filtration system(s) CS-1 Cyclones(1D-31)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
j hour regardless of the number of gin stands
and/or modified or new facilities constructed
j after July 1, 2002]
i Observed Operating V.E. 15%
3) Inspection Conference:
On 21 November 2013, I Mike Thomas of FRO DAQ conducted a compliance evaluation inspection of
the Piedmont Cotton Inc. facility. I met with Mr. Robert Williamson Jr.,Manager at the facility. Mr.
Williamson verified that the FACFINDER information was correct and current.
Piedmont Cotton Inc.,began ginning on the first of November 2013. The new season baseline was
performed by Rafe Dixon 9 October 2013. Pressure checks occur monthly. Overall, ginning has
occurred every weekday,as well as some Saturdays. 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.
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.
There have been no new system designs or equipment changes prior to this gin season;only routine maintenance
was done.
4) Walk Through:
Mr. Williamson led me on a tour of the facility starting with the cyclones behind building. The cyclones
appeared to be in good shape and had recently been painted. 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 them. Mr.Williams said that they fill the waste truck
twice a day. The waste is hauled off by local farmers. We then proceeded inside the ginning building. All three
of the gin stands were operating during the inspection. Mr. Williams 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 REOUH2EMENT-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-313 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 October 2013 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 1 March 2013 and appeared in compliance because 18,000
bales were produced with a 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 GINREOUIREMENT—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 15ANCAC20.050I(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
a) 21 November 2001 —NOV for"Failure to Operate and Maintain the Facility".
b) 6 March 2001 —NOV/NRE for"Open Burning Cotton Trash".
c) 16 November 1998—NOE for"Open Burning Cotton Trash".
7) Comments and Compliance Statement
This facility has had problems in the past with cotton trash build-up on the property.Mr. Williamson has done a
much better job of cleaning up the trash on the gin's grounds.

During the next compliance inspection in 2013,the inspector should ensure that the facility has not replaced
any of the current cyclones with larger capacity ones
Piedmont Cotton,Inc. appeared to be in compliance on 21 November 2013.
/mst