AQ_F_0400044_20101020_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: 10/21/2010
Facility Data Compliance Data
Piedmont Cotton Inc Inspection Date 10/20/2010
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 Authorized Contact Technical Contact permit 08152/G03
Robert Williamson,Jr. Robert Williamson,Sr. Robert Williamson;Jr. Issued 8/15/2007
Gin Manager President Gin Manager Expires 7/31/2012
[phone] [phone] [phone] Classification Small
Permit Status Active
Inspector's Signatur.pl Comments:
Date of Signature:
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 at Old Wire Road (Hwyl44) and go approximately
11 '/2 miles to Laurel Hill. Turn right at Hwy 74, go approximately 35 miles west through Wadesboro, and
continue about another 5 miles until Poplar Hill Church Road. Turn left and go almost ''/2 mile until Cotton
Street. Turn right, and facility entrance will be on left hand side, approximately .2 of a mile.
Safety Considerations: Safety shoes,safety glasses and earplugs(if operating).Hardhat is optional. Watch for
trucks entering and leaving,as well as cotton module trucks coming into and out of warehouse.
2) Facility Description
Piedmont Cotton,Inc. is a cotton ginning operation that produces raw cotton for industrial use. This facility
is permitted under Air Permit No. 08152G03, effective from 15 August 2007 until 31 July 2012. Cindy
Grimes conducted the last compliance inspection on 4 November 2009.
a) Throughputs for 2009
Employees: 9 (5 in 2009)
Hours: 8:OOAM—8:00 PM, Wed—Sundays (only on weekends in 2009)
Bales in 2009: 1,946(5,404 in 2008)
Projected Bales: 8,000 (3,500 in 2008)

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(ID-3D and 2D-21)
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 upon entry. It had rained recently, so the haul roads
were sufficiently damp.
b) Inspection Conference: On 20 October 2010,I (Cindy Grimes)met with Robert Williamson, Jr., the
Facility and Authorized Contact, and we discussed the following:
1) Piedmont Cotton began ginning on 18 September 2010. They plan to end the season by 30
November 2010.
2) This gin is rated at 35 bales/hr(3 gin stands, each @ slightly more than 11 bales/hr).
3) 1 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 on 17 October 2010,with a tape repair of a small hole in one of the ductwork
pieces.
4) Rafe Dixon performed their baseline study on 18 September 2010.All static pressure readings%were
within the defined operating range.A second monthly static pressure test was done on 15 October
2010 by Mr. Dixon, and again, all were within acceptable range.
5) Verified the FACFINDER information,with Mr.Williamson being the sole contact.
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 damp,with a slight drizzle/mist.
2) All cyclones are either 1D-31)or 2D-2D in size.
3) All rain caps have been removed.
4) The trash collection area is composed of an enclosed trash house that dumps from the bottom into a
trailer.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%. At some point in the
future,Mr.Williamson wants to install a reclaim system within this area so as to reclaim more trash
at one time.

5) The gin's overall appearance was good. They no longer have a problem with trash build-up behind
the gin as in years past. They switch out a trash truck anytime from approximately every 3 hours to
every 2-3 days, depending on the quality of the cotton and/or the amount of cotton being ginned.
6) I observed two haul trucks, and both 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 done 2 static
monthly pressure checks so far(18 September and 15 October).
2) I reminded him that their annual report is due by March 1, 2011;FRO DAQ received this year's
report on 18 February 2010.
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 leas
not happened. If the ginning continues to increase in the future,he might be able to do this next
year.
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.
In Compliance—The facility was operating during my inspection;I observed no visible emissions greater
than 20%VE from any of the emission sources.
b) A.4 2D .0521 VISIBLE EMISSIONS CONTROL REQUIREMENTS—Visible emissions fi-om
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.
In Compliance—All equipment at this facility has been manufactured since July 1, 1971,thus is subject to
the 20%opacity standard.
c) A.5 2D.1806 CONTROL AND PROHIBITION OF ODOROUS EMISSIONS-The Permittee steal l
not allow odorous emissions beyond the facility's boundary.
In Compliance—I detected no objectionable odors on site during my inspection or at the facility's
boundary.
d) A.7 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).
In Compliance—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 18
September 2010, static pressure checks are perfonned 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 by 1 March 2010, and past records are retained in main office.

e) A.8 2D .0310 COTTON GIN REQUIREMENT—Facility will not operate any emission sources other
than those that are permitted.
In Compliance—Facility is only operating permitted emission sources.
f) A.9 2Q .0806 LIMITATION TO AVOID 15A NCAC 2Q.0501(PROHIBITORY SMALL)—
Facility-wide potential PM10 shall be less than 100 tons per consecutive 12 month period and gin
= productim4ess4har 1=6W;D00=bales=of=cotton-er-=consecutive—.12--month-period;-.annual_rep_ort.-shall
contain number of bales produced, with records to be maintained documenting such.
In Compliance—Inspection showed that the facility and all observed equipment appeared to be
compliant and only operating permitted emission sources (e.g. VE from cyclones was<20%).
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/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 last year and this
year's inspections, it appeared that Mr.Williamson has done a much better job of cleaning up the trash on the
gin's grounds.
Piedmont Cotton,Inc. appeared to be in compliance on 20 October 2010.
/clg
cc: DAQ Central Files

DAQ 2010 Cotton Gin Insp Form Final
Page I
DAQ Cotton Gin Inspection Plan
for 2010
Inspector Prep and Checklist:
_ (1)Copy of Current Permit
_ (2)Copy of Reg*
(3)_Cop_y of DAQ Reg_Summary*
(4)Copy of DAQ Suggested Logform*
(5)Copy of DAQ Airflow Measure Guides,including the Method 1-2 form from 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 ��►^_��� � .vti County Premise C I 0 v G �(
I. Entry pon
Make the following observation on the surveillance drive around and your initial entry.
1. Observe general yard appearance:
a) Are good housekeeping practices being done in
Non-storage areas? S
Overall yard?
Are cyclone banks caked with dust?
Do nearby trees/vegetation have dust? v,�
b) Are speed limit signs posted on unpaved roadways? �s 2—
���h)or
_ (indicate speed and#of signs)
[15 mph for wet suppression o 0 chemical suppression]
c) Are transport (trash or non-module trucks) vehicles covered before leaving facility?
C._s
IL Inspection Conference
New rule effective date: 1 August 2002
1. Plant Contact and Title L-1 i�tl;
2. Date cotton ginning began
3. What is Gin's Maximum Rated Capacity
How determined?
Number of gin stands -3 Rated capacity of each
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: �i-1 L

DAQ 2010 Cotton Gin Insp Form Final
Page 3
Examine static pressures.
Any out of range? Corrective Actions
Appear to be in compliance with rule q kj'
Note: change of static pressure of>20%, then initiate corrective action.
(a)corrective action shall be recorded in logbook
(b) if> 48 his 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? al-u'1 .r�1 �1 i?.cz_, How is form signed?
What time each day t C'?_t I A.,ri
Is Logbook entry complete?
(see DAQ recommended form for nece. items)
v. A copy of the manufacturer's specifications for each type of control device installed.
l.Coy of the inspection and maintenance schedule for the control devices, other emission
processing equipment,and monitoring devices. This was to be established and based on
manufacturer's recommendations. �^
AND
2.Results of the inspections and any maintenance performed
*3. Repair Schedule from previous Season (if applicable). Verify that problems
and repair identified have been resolved per schedule
D
The following three items are recommended to be placed in the logbook.
vi. copy of regulation 2D.05421 ;�
vii, copy of current permit
viii. copy of annual reports submitted to DENR
*Inspector: Yi'here is- logbook kept? Evaluate how cgnvenient the logbook is for every
day use. t <�
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? \�e�
2. Cyclones. _
Are all cyclone I D 3�;or 2D-2D? t i�
if no, tyen i�tif�
How is each in compliance with reg

DAQ 2010 Cotton Gin Insp Form Final
Page 5
IV. Exit Conference
In addition to your normal observations, note the following areas and issues
1. Discuss Discrepancies
2. Restate any required information you requested, and/or any actions to be performed on or
before agreed date.
3. Reminders:
b) Annual report due on 1 March a X /
2�3 i t