AQ_F_0400044_20111018_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: 10/19/2011
Facility Data Compliance Data
Piedmont Cotton Inc Inspection Date 10/18/2011
195 Cotton Street Inspector's Name Cindy Grimes
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 Antho•ized Contact Technical Contact permit 08152/G03
Issued 8/15/2007
Robert Williamson, Jr. Robert Williamson,1r, Robert Williamson,Jr. Expires 7/31/2012
Gin Manager President Gin Manager Classification Small
[phone] [phone] [phone] Permit Status Active
Inspector's Signature, Co n cents:
l/ `fi
Date of Signature: t o( 4
MACT/GACT Applicability: None.
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 '/2 miles
to Laurel Hill.Turn right at Hwy 74, go—35-miles west through Wadesboro,and continue—5 miles until
Iroplar 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 coning 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 tinder Air Permit No. 08152G03, effective fi•om 15 August 2007 until 31 July 2012. Cindy
Grimes conducted the last compliance inspection on 20 October 2010.
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.

are 4 main systems included in theof mina of sotto i• al Chad eotton elea vino-involves n 60,ing to vrl Lice
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 2010
Employees: 9 (same in 2009)
Hours: 8:OOAM—8:00 PM,Mon —Fridays Only on weekends in 2009)
Bale Production in 2010: 8,916 (1,946 in 2009)
Projected Bales for 2011: 16-18,000(8,000 for 2010)
b) Permitted Sources
Emission Emission Source Control Control System
Source ID Description System Ill Description
CG-1 Emission sources and air filtration system(s) CS-1 Cyclones(ID-3D and 2D-2D
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 Surnmary
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 18 October 2011, I (Cindy Grimes) met with Robert Williamson, Jr., the
Facility and Authorized Contact, and we discussed the following:
1) Piedmont Cotton began ginning on 19 September 2011.They plan to end the season —30 November
2011. 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/fir).
3) I examined the walk-around logbook and found entries for each day of operation so far. AI I entries
appeared complete,with ductwork, cyclone,trash stacker, yard and other notations. The most recent
entry was on 18 October 2011,with a duct tape repair of a small pinhole in one of the cyclones.
4) Rafe Dixon 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 clone on 12 October
2011 by Mr. Dixon, and again, all were within acceptable range.
5) Production usually averages—221 bales per 12 hour shift,though in the last 8 clays, production has
been—350 bales per day.

7) This was the facility's permit renewal compliance inspection.Mr. Williamson will be getting the
renewal letter-31 January 2012, and the letter will give instructions on how FRO DAQ will want the
gin to complete its application forms and emissions inventory. I told him to call me if lie had any
questions.
c) Inspection Walk-around (facility was operating)
1) All cyclones appeared to be less than 20%VE(actual VE was b/t 10-15% for each cyclone). At the
time of inspection,the weather was mostly sunny(the trash cyclone was 15%and all of the others
were 10%).
2) All cyclones are either ID-313 or 2D-2D in size.
3) All rain caps have been removed.
4) The trash collection area is composed of 3-sided enclosed trash house that dumps from the bottom
into atrailer.Water is added along the opening at the bottom of the dump bins. I observed the water
being sprayed in this area, and it seemed to be doing a good job; VE here was 5%.
5) The gin's overall appearance was good.In the past, there have been problems with wash build-up
behind the gin,but I did not observe a problem during this inspection. At the current ginning rate,they
are switching out a trash truck 3-4 times/day,which will eventual ly slow down to every 2-3 days. This
depends on the quality of the cotton and/or the amount of cotton being ginned.
6) Iobserved three haul trucks, and all were 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.They have had 2 static monthly
pressure checks done so far(15 September and 12 October).
2) I reminded him that their annual report is due by March 1, 2011; FRO DAQ received this year's
report on 10 March 2011 (not considered late since it was postmarked 25 February).
3) For the last couple of years,Mr. Williamson has had plans to add a larger cyclone fan for air handl ing,
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 fi-om
emission sources manufactured after July 1, 1971 shall be no more than 20% opacity.
Compliance Indicated—The facility was operating during my inspection; I observed no visible emissions
greater than 20%VE from any of the emission sources.
b) AA 2D .0521 VISIBLE EMISSIONS CONTROL REQUIREMENTS—Visible emissions from
emission sources manufactured as of July 1, 1971,shall be no more than 40% opacity; verification of
manufacture date with ID numbers for subject equipment shall be kept on site,or facility can opt for the
20% opacity standard.
Compliance Lrdicated—All equipment at this facility has been manufactured since July 1, 1971, thus is
subject to the 20% opacity standard.

not allow odorous emissions beyond the facility's boundary.
Compliance Indicated-I detected no objectionable odors oil site during my inspection or atthe facility's
boundary.
d) A.7 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(fioni 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 ID-3D 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 range
measurements were performed, daily inspections are performed by Robert Williamson, Jr. (gin
manager), all observations and inspections are recorded in one logbook, latest annual report was
compliant and submitted on time, and past records are retained in main office.
e) A.8 2D .0310 COTTON GINREQUIREMENT-Facility will not operate any emission sources other
than those that are permitted.
Compliance Indicated-Facility is only operating permitted emission sources.
f) A.92Q .Q806 LIMITATION TO AVOID I5ANCAC2Q.0501(PROIIII3ITORY SMALL)—
Facility-wide potential PMIO 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
PMI O emissions; latest annual production (2010)was 8,916 bales;latest annual report showed bale
production; facility office keeps records that maintain production and gin reports.
5) Reporting Requirements
Annual report is due by March 1 of each year. See permit for specifics.
6) Compliance History
a) 21 November 2001 -NOV for"Failure to Operate and Maintain the Facility".
b) 6 March 2001 -NOV/NRB for"Open Burning Cotton rash".
c) 16 November 1998-NOB for"Open Burning Cotton Trasb".
7) Comments and Compliance Statement
This facility has had problems in the past with cotton trash build-up on the property. During last year and this
year's inspections, it appeared that Mr. Williamson has done a much betterjob 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.Also,the facility will have received its new permit before
the next inspection; therefore, any new information/stipulations should be discussed with facility.
Piedmont Cotton,Inc. appeared to be in compliance on 18 October 2011.
/clg
cc: DAQ Central Files

DAQ 2011 Cotton Gin Insp Form Final
Page 1
DAQ Cotton Gin Inspection Plan
for 2011 _ _ 1011OZA11
Inspector Prep and Checklist:
(1)Copy of Current Permit
(2)Copy of Reg*
(3)Copy of DAQ Reg Summary*
(4)Copy of DAQ Suggested Logform*
(5)Copy of DAQ Airflow Measure Guides, including the Method 1-2 form fi•om website
(6)Copy of compliance certif.letter submitted to regional office
(7)Copy of Repair Schedule from last annual report
(8)Tape Measure
*may want to have extra copies to be able to leave with gin operator
Name of Cotton Gin County Premise oL4 c�4f
I. Entry
Make the following observation on the surveillance drive around and upon your initial entry.
1. Observe general yard appearance:
a) Are good housekeeping practices being done in
Non-storage areas? ucs
Overall yard? V
Are cyclone banks caked with dust? i<v
Do nearby trees/vegetation have dust9 V
b) Are speed limit signs posted on unpaved roadways? Un S Z
(indicat—r e speed and#of signs)
[15 mph for wet suppression or 0 mph r chemical suppression]
c) Are transport (trash or non-module trucks) vehicles covered before leaving facility?
%� C
II. Inspection Conference
New rule effective date: 1 August 2002
1. Plant Contact and Title olac,-l'1 f I Lia-. ot...l + -
2. Date cotton ginning began 9 111 1Z_z)[ I
3. What is Gin's Maximum Rated Capacity :3 3.
How determined?
Number of gin stands 3 Rated capacity of each �1 b 1-v
Have any changes been made to gin stand(s) that increased the bale/hr capacity?
(Only for gins that are rated under 20 bales/hr)
Production: Bales last year: ?, 9 t(e

f
DAQ 2011 Cotton Gin Insp Form Final
Page 2
Expected Bales this season ],(,�i$i uvO
Hours of operation (days, Ins) M>t6- g Atl- e e M &-6 > S��
Estimated end of season o,-J't S'e\r- Z-Z1 k
4. Are all cyclones installed to meet the final requirements of 2D.0542? }es ro
IF no, what else is required
[see summary or rule for detail]
What type of control do you have on?
Lint Cleaners 1 '�, -3-D clot or mesh, if mesh then size
Battery Condensers k D�3�II clop or mesh, if mesh then size
5. Do you have sources that were manufactured as of July 1, 1971 yes/®
If yes, is your facility opting to have these sources subject to the 20%opacity standard yes/no
If no does your facility have the following monitoring and recordkeeping requirements for all
subject equipment
i. verification of the date of manufacture yes/no
ii. labels on Subject equipment and all associated control equipment yes/no
6. Examine logbook. And discuss all aspects of what is in logbook.
Who is responsible for book? Where is it kept? Vy�z.w 1, ld]��a ° _
Note do this prior to walking around.
The logbook(s)shall be maintainer/on site and Hanle available to Division representatives upon request
Records not on-site should be violation.
i. Results of the New Season baseline study. Date conducted
Who conducted study
Do you have monitoring equipment on site? u e_r
Was EPA Method 1 and 2 used for any measurements? LIM-
Were all required items measured for each control device
Inlet velocity �4 R f
Static pressure c
Pressure drop
Appear baseline conducted properly?j,-.f
[will need to evaluate ports and locations during inspection]
Examine air flow design ranges; are any out of range y ,)
[air flow design ranges:213-213(2700 to 3600 fpm), ID-3D(2800 to 3600 fin)]
Request copy of this baseline study (copy on site if possible)
(if no copy, have a copy sent asap)
ii. Has any part of collection system been changed or redesigned since baseline study?
(such as new control devices, new fans, etc.) YO C-La4- er
Results of new baseline study(conducted if there is a design change)
iii. Results of monthly static pressure checks and any corrective action taken
How will company conduct these monthly measurements:
_\ �0 11 5 e ✓c n ZJ

DAQ 2011 Cotton Gin Insp Form Final
Page 3
Examine static pressures.
Any out of range? --yJ Corrective Actions -
Appear to be in compliance with rule uaf
Note: change ofstatic pressure of>20016, then initiate corective action.
(a)corrective action shall be recorded in logbook
(b) if> 48 hrs to complete, notify RAQS asap, no later than end of day such pressure was measured.
iv. Observations from daily inspections of the facility and any resulting corrective
actions taken (inspect structural integrity of the control devices and other emissions
processing systems)
Who does the walk around? i Il.w.-S How is form signed?
What time each day - to -t1 ic�M
Is Logbook entry complete? �4 p,J
(see DAQ recommended form for necc. items)
v. A copy of the manufacturer's specifications for each type of control device installed.
1.Copy of the inspection and maintenance schedule for the control devices, other emission
processing equipment,and monitoring devic . This was to be established and based on
manufacturer's recommendations.
AND
2.Results of the inspections and any maintenance performed
Ae.�
*3. Repair Schedule from previous Season (if applicable). Verify that problems
and repair identified have been resolved per schedule
The following three items are recommended to be placed in the logbook
vi. copy of regulation 2D.0542, �tS
vii. copy of current permit
viii. copy of annual reports submitted to DENR y tj
*Inspector: Where is logbook kept? Evaluate how convenient the logbook is for every
day use.
III. Inspection Walk around
In addition to your normal observations,note the following areas and issues
1. Normal evaluation includes:
a) VE at all sources.
b) holes (and patches) in ductwork. Are they reflected in the daily log? kt.ts
2. Cyclones.
Are all cyclone 1D-3D r 2D-2D? I a>
if no, then identi y
How is each in compliance with reg

DAQ 2011 Cotton Gin Insp Form Final
Page 4
3. Mesh Screen.
- If used on exhaustfrom lint cleaning and/or battery condensers, what size
Try to examine to get a better understanding.
4. Rain cap Removal
Examine exhausts. Is any type of`lid' still present? Yw
Is air deflected downward or outward
5. Baseline Study
Evaluate the baseline study by examining the ports. Know which method(s) they used. Use
tape measure to calculate/estimate whether the ports met the requirements; measure
duct size and distances (cotton gin handbook method requires 1.5 duct diameters and 8.5 d.d.)
V1_4_4 aCNI�
6. Trash Collection and Stacker
What type of trash stacker system is present? Three types in rule:
— --> Observations:
( 3 sided with roof g w ct- Ua+N I's
(2) Wet suppression at auger and dump area
(3) Trash stacker/composter- water in auger box,
water at dump area, pile kept wet at all times
(4) Other ? if so specify.
7. Trash Collection Area:
a) is overspill removed from truck before transporting? 4e-,r
b) Examine how trucks are covered?
Do all trucks have covers? If not, question how it is covered prior to transport?
4e_5
c) Is trash collection a�ea cleaned daily? W at time nil by who?
d"`i pyp��2
8. Unpaved Road Dust Suppression.
Are unpaved roads being adequately controlled with we r chemical suppression?
How is wet or them. suppression applied d-P wo
What schedule and by who Mv.wd 1 „ sr -h� ? Pr (< f 4L�)

iDAQ 2011 Cotton Gin Lisp Form Final
Page 5
IV. Exit Conference
In addition to your normal observations,note the following areas and issues
_ t
1. Discuss Discrepancies
2. Restate any required information you requested, and/or any actions to be performed on or
before agreed date.
3. Reminders: Zo w
b) Annual report due on 1 March.200K-