AQ_F_0900052_20101028_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Fayettevill7Regional Office
AIR QUALITY Clarkton CNC Facilit52
Inspection Report County/FI017
Date: 11/02/2010
Facility Data Compliance Data
Clarkton Cotton Co Inspection Date 10/28/2010
9292 Highway 701 South Inspector's Name Pam Vivian
Clarkton,NC 28433 Operating Status Operating
Lat: 34d 30.1940m Long: 78d 39.4490m Compliance Code Compliance-inspection
SIC: 0724/Cotton Ginning Action Code FCE
NAICS: 11511 l /Cotton Ginning On-Site Inspection Result Compliance
Contact Data Permit Data
Facility Contact Authorized Contact Technical Contact Permit 07070/G06
John Cox John Cox John Cox Issued 8/15/2007
Vice President Vice President Vice President Expires 7/31/2012
[phone] [phone] [phone] Classification Small
Permit Status Active
Inspector's Signature: >)a Comments:
Date of Signature: I!f 1 °/Z ev C/
NE,SHAP: At the time of this inspection, this facility does not appear to be applicable to any of these
regulations. The facility also does not have any emergency generators on site.
Directions:
From FRO, take Hwy 87 south and travel about 35 miles toward Elizabethtown. On Hwy 87 south bypass turn
right at stoplight onto Hwy 701 south and travel about 6miles. Gin is on the right across from EJ Cox Peanut
Processing.
Safety Considerations: Safety shoes, glasses, and earplugs. Hardhat is not necessary. Be aware of the forklifts
and cotton trucks entering,unloading and leaving facility area. Also, inspectors entering waste area may require
a fiber mask due to floating particle matter.
Facility/Process Description:
Clarkton Cotton Co. is a cotton ginning operation that receives seed cotton in large modules. The seed
cotton enters a gin stand where several parallel saws separate the cotton lint from the cottonseeds and plant
debris. Moisture is also removed as the process continues. The plant debris are transported through ducts to
the waste building. The waste can be recycled in fields as mulch and fertilizer. Some waste becomes fodder
for cattle. The cottonseed is sold to other companies for various industrial products and fodder for cattle.
The cotton lint is processed with further cleaning,moisture removal, and develops into batt or matted lint
cotton. The halt is pressed into rectangular bales and weigh,about 500 pounds. The bales are wrapped,sold,
and shipped to various yarn mill manufacturers.

Permitted Sources:
Emission ( Emission Source Control Control System
Source ID Description System ID Description
- - - __ - - --- - _-- ------
CG-1 Emission sources and air filtration systems) CS 1 Cyclones(1D-3D and 2D-2D
utilized in the cotton ginning process (Standard cyclones typical per 2D.0542)
hrdustrial 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]
Throughputs for 2009:
Employees: 7 (when operating), 1 during off season
Hours: 7:OOAM-7:OOPM, Mon -Fri; occasionally Sat.
Bales: 2009- 11,114
Projected bales: 2010- 12,000- 13,000
Inspection Checklist:
See attached checklist.
Checklist Summary:
Entry: I observed a clean appearance about the facility property in general (no Spanish moss, or
accumulations of excess dust on surrounding property).One speed]imit sign is posted on the property stating
15 mph along entrance haul road,which also functions as the facility exit. This facility has a water truck for
spraying the gravel/dirt haul road, and no excess fugitive dust emissions were observed, nor any tracking on
Highway 701, but the area was wet appearing from recent rain. The gin was not operating during the
inspection.
Inspection Conference: I met with Bob Goodman, Senior Plant Operator who was in the office doing
various book-keeping and payroll. He said Mr. Cox hadjust left the facility about 20 minutes ago to attend
to some personal matters. We discussed the following:
Ginning started on 15 September 2010 and Mr. Cox performed the gin's new season initial static pressure
checks on this same day. All readings appeared to be within the defined operating range. He said the plant
hadjust closed at around 3:30 pm due to no cotton modules available to process. He said until more modules
are brought in from the fields they could start back up on Monday, 1 November 2010.
This ginning operation is rated at 34 bales per hour(2 gin stands at 17 bales/hr);there are cyclones on the lint
cleaners and battery condensers.
The daily walk around logbook had entries for the day when operation was possible and is done and initialed
by Mr. Cox and sometimes by Mr. Goodman, around 7:30 am. There were entries for when the yard/haul
road wet down. Small patch repairs for duct work and yard clean up were also recorded. The area has
received a lot of rain since start tip which has slowed the harvesting, thus the ginning process, but it appears
the season will be better than last year.

Records indicate Mr. Cox does the monthly static pressure checks and the last record indicated 13 October
2010 it was performed.
Facility Inspection:
All cyclones are either 1D-313 or 2D-2D in size.
All rain caps have been removed.
Trash collection is composed of a trash stacker/composter. Inside the trash house, water is added at the auger.
I did not observe any trucks entering or leaving the facility. I did not see any modules waiting to be ginned,except
for one very small and irregular shaped module but Mr. Goodman said that one was not going to be ginned
because of it lack of quality. The facility processing area was clean and appeared maintained.
Exit Conference:
I told Mr. Goodman that everything appeared to be compliant and in order.
I reminded him in order to avoid another NOV for late reporting,to tell Mr. Cox the annual report was due by
1 March 2010.
Permit Stipulations
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 this inspection with no visible emissions greater than
20%VE from any of the emission sources.
b) A.4 2D .0521 VISIBLE EIIISSIONS 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.
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 shall
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 brash material),monitoring(includes baseline
studies, static pressure checks, and daily inspections), recordkeeping, reporting, record retention, and
alternative control measures(see perinit for details).
In Compliance—Facility uses 113-31)cyclones, rain caps are removed, logbook contains daily
inspections/maintenance,trash collection house has wet suppression, gin yard is cleaned daily,wet
suppression is used in traffic areas and there are 15 mph signs, haul bucks are covered,facility has
monitoring devices that measure static pressure and flow rates,initial baseline study was done on 15
September 2010, static pressure checks are performed every 30 days, initial flow range measurements
were performed, daily inspections are performed by Mr. Cox or Mr. Goodman,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(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.
In Compliance—Latest permit review show compliance; annual report stated that 11,114 cotton bales
were ginned in 2009 (well below the Limit of 167,000), with facility having documentation showing
compliance.
Reporting Requirements:
Due 1 March of each year(see permit for specifics). Annual report for 2009 received at FRO 23 February
2010,
Five Year Compliance History:
On 3 April 2009 an NOV was submitted for late reporting of 2008 year-end requirements(see permit for
specifics).
Conclusion and Compliance Statement:
At the time of this inspection, this facility appeared to be operating in compliance.
/pcv
cc: Central Files

DAQ 2010 Cotton Gin Insp Form Final
Page 1
DAQ Cotton Gin Inspection Plan
for 2010
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 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
J
Name of Cotton Gin 1 i,4 t4 0 u) County Premise V y (P0J z
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? f
Overall yard?
Are cyclone banks caked with dust? to o
Do nearby trees/vegetation have dust? k V
b) Are speed limit signs posted on unpaved roadways? V P
(indicate speed and#of signs)
[15 mph for wet suppression or 10 mph for chemical suppression]
c) Are transport (trash or non-module trucks) vehicles covered before leaving facility?
II. Inspection Conference
New rule effective date: 1 August 2002
1. Plant Contact and Title 06 6 6 oa,( m oetl
2. Date cotton ginning began 17 h s,/ f 0
3. What is Gin's Maximum Rated Capacity 6 V. �/ 2
How determined? M yr' o
Number of gin stands .2 Rated capacity of each ! R/ T
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 Ih

DAQ 2010 Cotton Gin Insp Form Final
Page 2
Expected Bales this season / 2 _/ 3 K
Hours of operation (days, hrs) L fi M
Estimated end of season b e c z a/O
4. Are all cyclones installed to meet the final requirements of 2D.0542? Yes
IF no, what else is required
[see summary or rule for detail]
What type of control do you have on?
Lint Cleaner's (c i ie) or mesh,if mesh then size
Battery Condensers --cyclono, or mesh,if mesh then size
5. Do you have sources that were manufactured as of July 1, 1971 s no
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 _���/no
ii. labels on subject equipment and all associated Toidrol equipment _-C'�*/no
6. Examine logbook. And discuss all aspects of what is in logbook.
Who is responsible for book? Where is it kept? 1'14 2 C v 9 A !�(�e J,6,Z we,.
Note do this prior to walking around.
The logbook(s)shall be maintained on site and made available to Division representatives upon request.
Records not on-site should be violation.
i. Results of the New Season baseline study. Date conducted r/h s/i i>
Who conducted study Me/`a v
Do you have monitoring equipment on site? /V O
Was EPA Method 1 and 2 used for any measurements?
Were all required items measured for each control device :
Inlet velocity
Static pressure
Pressure drop
Appear baseline conducted properly? S
[will need to evaluate ports and locations during inspection]
Examine air flow design ranges; are any out of range N 0
[air flow design ranges:2D-2D(2700 to 3600 fpm), 1D-3D(2800 to 3600 fpm)]
Request copy of this baseline study(copy on site if possible) e
(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.) a; Q
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: owe, �'o r ('nn �wr/S

DAQ 2010 Cotton Gin Insp Form Final
Page 3
Examine staticpressures.
Any out of range? 1✓.61) Corrective Actions
Appear to be in compliance with rule
Note: change of static pressure of?�20016 corrective then initiate co action.
(a)corrective action shall be recorded in logbook
(b)if> 48 hrs to complete, notify PAQS 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 e Irf&9 W y am.1 How is form signed?
What time each day 7- 7; 3Q 4
Is Logbook entry complete? a <
(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 devices. This was to be established and based on
manufacturer's recommendations. V
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
-44-w A ry,u u a 1
The following three items are recommended to be placed in the logbook
vi. copy of regulation 2D.0542, v to S
vii. copy of current permit ;L f
viii. copy of annual reports submitted to DENR
*hispector: 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?y r f
2. Cyclones.
Are all cyclones ID-3D or 2D-2D? v) S
if no, then identify
How is each in compliance with reg n, a w'ijL� C h K r�1

DAQ 2010 Cotton Gin Insp Form Final
Page 4
3. Mesh Screen.
If used on exhaust from 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?
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.)
6. Trash Collection and Stacker
What type of trash stacker system is present? Three types in rule:
Observations:
(1) 3 sided with roof
(2 'Wet suppression at auger and dump area
(3)Trash stacker/composter,= water injuger 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?y s
b) Examine how trucl s-are-covered?
Do all trucks Ke covers? if not, question how it is covered prior to transport?
c) Is trash collection area cleaned daily? What time and by who?
yes / k-"lIoy, e
8. Unpaved Road Dust Suppression.
Are unpaved roads being adequately controlled wit]�wet,gi chemical suppression?
How C(we�Chem. suppression applied b��� P d
What schedule and by who A5Ne lei Y)y)�eo/dk -eLc

DAQ 2010 Cotton Gin Insp Form Final
Page 5
IV. Exit Conference
In addition to your norm7Ial observations,note the following areas and issues
/UOrU-� /NUll � �
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 Marclt720�3£