AQ_F_0400044_20121107_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: 11/08/2012
Facility Data Compliance Data
Piedmont Cotton Inc Inspection Date 11/07/2012
195 Cotton Street Inspector's Name Robert Hayden
Polkton,NC 28135 Operating Status Operating
Lat: 34d 59.7360m Long: 80d 12.4970m Compliance Code Compliance-inspection
SIC: 0724/Cotton Ginning Action Code FCE
NAICS: 115111 /Cotton Ginning On-Site Inspection Result Compliance
Contact Data Permit Data
Facility Contact Authorized Contact Technical Contact Permit 08152/G04
Robert Williamson,Jr. Robert Williamson,Sr. Robert Williamson,Jr. Issued 7/16/2012
Manager President Manager Expires 6/30/2017
[phone] [phone] [phone] 1Classification Small
Permit Status Active
Inspector's Signature-
e � Comments:
Date of Signature: ,t
MACT/GACT Applicability: None.
1) Directions
Piedmont Cotton is I at 195 Cotton Street, in Polkton,NC,Anson County. From FRO,take Hwy 401
South to Wagram. Turn right onto Old Wire Road(Hwyl44)and go— 11 1/2 miles to Laurel Hill. Turn
right at Hwy 74,go—35 miles west through Wadesboro,and continue—5 miles until Poplar Hill Church
Road(BJ's 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. 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, and cotton
seeds as a byproduct, sold for cattle fodder. This facility is permitted under Air Permit No. 08152G04,
effective from 16 July 2012 until 30 June 2017. Cindy Grimes conducted the last compliance inspection
on 18 October 2011.
Module trucks and trailers transport cotton modules(brick-shaped and cylindrical)from the field to the
gin.A pneumatic system removes the cotton from the trailers, and either a pneumatic system or a module
feeder pulls the cotton from the 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 2011
Employees: 9
Hours: 8:OOAM—8:00 PM,Mon—Saturdays during ginning season
Bale Production in 2011: 17,905
Projected Bales for 2012: 16-18,000. The crop is better, but there is less acreage this year
b) Permitted Sources
Emission Emission Source Control Control System
Source ID Description System ID _� Description
CG-1 Emission sources and air filtration system(s) CS-1 Cyclones(1D-3D and 2D-2D
i utilized in the cotton ginning process,(Standard cyclones typical per 2D.0542)
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]
3) Checklist Summary
a) Entry: I observed a clean appearance throughout the facility property in general. There was no
excess dust accumulation on surrounding property or vegetation upon entry. The haul roads were
sufficiently damp because the facility's water truck had been used earlier in the AM.
b) Inspection Conference: On 7 November 2012,1, Robert Hayden met with Robert Williamson,Jr.,the
Facility Contact. He examined the FacFinder data and suggested that the air permit consultant,Rafe
Dixon,be listed as the Technical Contact. Mr. Dixon was informed of that on 9 November and
FacFinder was edited accordingly. Mr Williamson and I then discussed the following:
1) Piedmont Cotton began ginning on 15 October 2012.They plan to end the season—22 December
2012. There have been no equipment changes since the last compliance inspection.
2) This gin is rated at 35 bales/hr(3 gin stands, each @ slightly more than 11 bales/hr).

3) I examined the walk-around logbook and found entries for each day of operation so far. All entries
appeared complete,with ductwork, cyclone,trash stacker,yard and other notations. The most recent
entry was that day,with no issues found.
4) Rafe Dixon(consultant)performed their baseline study on 15 September 2011. All static pressure
readings were within the defined operating range.A second monthly static pressure test was done on
6 November 2012 by Mr. Dixon,and again,all were within acceptable range.
5) Production usually averages—220 bales per 12 hour shift,though in the last 3 days,production has
halted because of a part failure. The plant was not operating at all,and awaiting a part from
Alabama.
c) Inspection Walk-around (facility was not operating)
1) There was no evidence of excess emissions around the cyclones.
2) All cyclones are ID-3D.
3) All rain caps have been removed.
4) The trash collection area is composed of a 3-sided enclosed trash house that dumps from the bottom
into a trailer. Water is added along the opening at the bottom of the dump bins.
5) The gin's overall appearance was good. In the past,there have been problems with trash build-up
behind the gin,but I did not observe a problem during this inspection. When operating at full
capacity,they switch out a trash truck 3-4 times/day, depending on the quality of the cotton and/or
the amount of cotton being ginned.
6) I one haul trucks at the load-out, empty, so not covered.
d) Exit Conference
1) Mr. Williamson and I discussed the baseline study, and I reminded him to make sure that the
monthly static pressure checks are done within 30 days of each other.
2) I reminded him that their annual report is due by March 1, 2013;FRO DAQ received this year's
report on4wA4fweh 2012. 9It eC,71&T-Un F_Y
3) For the last.couple of years,Mr. Williamson has had plans to add a larger cyclone fan for air
handling,but due to the economy and small amount of cotton ginned the last few years,that has not
happened yet.
4) Permit Stipulations
(also, see attached inspection checklist)
a) A.3 2D .0521 VISIBLE EMISSIONS CONTROL REQUIREMENTS-Visible emission from
emission sources manufactured after July 1, 1971 shall be no more than 20%opacity.
Compliance Indicated—The gin was not operating,but there was no evidence of excess dust.
b) A.6 2D .0540 FUGITIVE DUST CONTROL. Must prevent excessive,non-process dust from
going offsite. Compliance Indicated. The roadway was damp with occasional puddles, indicating
routine watering, as there had been no recent rain. No dust complaints.

c) A.7 2D .1806 CONTROL AND PROHIBITION OF ODOROUS EMISSIONS-The Permittee
shall not allow odorous emissions beyond the facility's boundary.
Compliance Indicated—There is fermentation odor around the trash pile,but I detected no
objectionable odors on site during my inspection or at the facility's boundary.
d) 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(see permit for details).
Compliance Indicated—Facility uses 1D-31) cyclones,rain caps are removed, logbook contains daily
inspections/maintenance,trash composter/stacker has wet suppression, gin yard is cleaned daily,wet
suppression is used in traffic areas and there are 10 mph signs,haul trucks are covered,facility has
monitoring devices that measure static pressure and flow rates, initial baseline study was done on 15
September 2011, static pressure checks are performed within every 30 days, initial flow rate
measurements were taken,daily inspections are performed by Robert Williamson,Jr. (gin manager).
All observations and inspections are recorded in one logbook. The latest annual report was compliant
and submitted on time(24 Feb),and past records are retained in main office.
e) A:9 2D .0310 COTTON GIN REQUIREMENT—Facility will not operate any emission sources
other than those that are permitted.
Compliance Indicated—Facility is only operating permitted emission sources.
f) A.10 2Q .0806 LIMITATION TO AVOID 1 SA NCAC 2Q.0501(PROHIBITORY 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.
Compliance Indicated—Inspection showed that the facility and all observed equipment appeared to
be compliant and only operating permitted emission sources. Latest permit review shows compliance
in PM10 emissions; latest annual production(2011)was 17,906 bales; latest annual report showed
bale production; facility office keeps records that maintain production and gin reports.
5) 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. During recent inspections,
it has appeared that Mr. Williamson has done a much better job of cleaning up the trash on the gin's grounds.
During the next compliance inspection in 2012,the inspector should ensure that the facility has not replaced
any of the current cyclones with larger capacity ones. The facility should be checked again this season while
operating to confirm opacity compliance.
Piedmont Cotton, Inc. appeared to be in compliance on 7 November 2012.