AQ_F_0400044_20221201_CMPL_CAV-Rpt

NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY Piedmont Cotton Inc
NC Facility ID 0400044
Inspection Report County/FIPS:Anson/007
Date: 12/01/2022
Facility Data Permit Data
Piedmont Cotton Inc Permit n/a
195 Cotton Street Issued n/a
Polkton,NC 28135 Expires n/a
Lat: 34d 59.7360m Long: 80d 12.4970m Class/Status Registered
SIC: 0724/Cotton Ginning Permit Status Inactive
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.
President President President
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 12/01/2022
Inspector's Name Mike Turner
Inspector's Signature: f �-j Operating Status Operating
Compliance Status Compliance- inspection
Action Code FCE
Date of Signature: �oZ � � 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 inpounds)
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

I. DIRECTIONS
From FRO,take Hwy 401 South to Wagram. Turn right onto Old Wire Road (Hwy144) and go— 11 '/z
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.
II. 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.
III. FACILITY/PROCESS DESCRIPTION
Piedmont Cotton, Inc. is a cotton ginning operation that produces raw cotton for industrial use. The
facility requested registration under 15A NCAC 02Q .0102 "Activities Exempted from Permit
Requirements"and DAQ issued the registration on 26 April 2017.
This facility operates three gin stands,each with a maximum rated capacity of 12 to 15 bales per hour
for a facility maximum rated capacity of 36 to 45 bales per hour. The facility combusts liquid propane
gas (LPG)to dry the cotton. Seasonal dry/wet weather condition determines combustion usage which
respectively ranges from 1.1 to 1.5 gallons of fuel per bale of ginned cotton. At present,the facility
operates seven parallel cyclones on each gin stand and one at the waste area for a total of 21 cyclones.
Each of these cyclones are ID-3D. Proper static pressure readings and visible emission observations
are used to maintain compliance with 2D.0542 regulations.
IV. ONSITE EMISSIONS SOURCES
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Emissions Sources Control Devices
Cotton Ginning Operations with maximum rated gin stand
Capacity greater than or equal to 20 bales per hour Cyclones
Not operating
V. COMPLIANCE ASSURANCE VISIT SUMMARY
On 1 December 2022,I, Mike Turner, of the Fayetteville Regional Office of DAQ, and Kris
Cornelius, also of FRO DAQ, conducted a compliance assurance visit of the Piedmont Cotton Inc.,
facility. We met with Mr. Robert Williamson Jr., President of the facility. We discussed the
following:
1. Mr. Williamson verified that the FacFinder information was correct.
2. Mr. Williamson stated the facility currently has 14 employees and operates Sam to 8pm Monday
through Saturday, and as needed on Sundays.
3. Mr. Williamson stated the 2022 season began on 3 October 2022, and he expects to gin
approximately 25,000 bales this season. He anticipates finishing this season around the end of
January.
4. Mr. Williamson stated the facility's mote is purchased by a company in India, as is the plastic
waste from the bales the gin takes in. Most of the gin trash is used by local farmers. The facility
also composts some of its trash, and that is used by local farmers and gardeners. The facility turns
the trash compost piles once a week. The cotton seed is used by dairy farmers in Virginia, Ohio,
and Wisconsin.
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d) Production:
Year Number of Bales
2021 20,607
2020 6,381
2019 20,136
2018 15,063
2017 12,126
2016 11,200
2015 10,876
2014 12,901
2013 6,290
VI. APPLICABLE AIR QUALITY REGULATIONS
1. 15A NCAC 2D .0521 VISIBLE EMISSIONS CONTROL REQUIREMENT—Visible
emissions from the emission sources shall not exceed 20% opacity.
APPEARED IN COMPLIANCE— The facility's cotton press was not operating when we arrived and had
not operated in 3 days, so the facility was not operating. We observed no visible emissions during our visit.
We observed no indications of previous issues with visible emissions. The overall yard and storage and
non-storage areas were clean and free of significant cotton accumulations. Nearby trees and vegetation
were also free of dust and cotton accumulations. The trash loadout areas, cyclones, and cyclone banks
were clean and well-maintained.
2. 15A NCAC 2D .0202 RECORD KEEPING—The Registrant shall maintain records on site to
establish that facility-wide annual air pollutant emissions remain below the 25 ton per year
threshold level listed above. Records(in written or electronic format) shall be maintained for a
minimum of two years and made available to DAQ personnel upon request.
APPEARED IN COMPLIANCE— We examined the logbook that Mr. Williamson maintains and
keeps in the office in the ginning building. The logbook is orderly and comprehensive, detailing
present and past I&M and yearly and monthly pressure checks going back several years. The
logbook showed beginning season baseline study was made on 3 October 2022 by Rafe Dixon,
and that ginning began on that day. Monthly inspections and static pressure measurements are
also made by Rafe Dixon. Mr. Williamson performs daily inspections for structural integrity.
Record retention requirements are being followed. The annual report for CY 2021 was received
in FRO on 4 February 2022 and the facility appeared in compliance with an annual production
of 20,607 bales. The facility also submitted a close of year inspection sheet stating that no repairs
would be needed before the next season.
3. 15A NCAC 2D .0202 NOTIFICATION REQUIREMENTS—The Registrant shall notify DAQ
as soon as possible of the following occurrences: Process Modifications: modification of the
processes from that listed in the "Emissions Equipment Table."Name/Ownership/Location
Change: upon changing the facility name, ownership or location from that as listed in this
Registration. Emissions Increase: if facility emissions increase such that the 25 ton per year
emission threshold would be expected to be exceeded. The Registrant shall notify DAQ prior to
exceeding this emissions threshold.
APPEARED IN COMPLIANCE—Mr. Williamson stated the facility has not changed any
processes, or added any equipment, that would increase emissions.

4. 15A NCAC 2D .0535 EXCESS EMISSIONS NOTIFICATION REQUIREMENTS—The
Registrant must report excess emissions of any regulated pollutant lasting more than four(4)
hours, and that result from a malfunction to the Division of Air Quality by 9 am of the next
working day.
APPEARED IN COMPLIANCE—Mr. Williamson stated the facility has not had any excess
emissions that lasted more than four hours, so no reporting has been necessary.
5. 15A NCAC 2D .0540 FUGITIVE DUST CONTROL REQUIREMENT—The Registrant shall
not cause or allow fugitive dust emissions to cause or contribute to substantive complaints or
excess visible emissions beyond the property boundary.
APPEARED IN COMPLIANCE— We observed no issues with fugitive dust beyond the
boundaries of the property. Mr. Williamson stated he has not received any dust complaints at the
facility and FRO has not received any dust complaints regarding this facility.
6.
15A NCAC 2D .0542 CONTROL OF PARTICULATE EMISSIONS FROM COTTON
> shall comply with
GINNING OPERATIONS For gins rated at 20 baleslhour,the Permittee sha
emission control requirements, 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 IN COMPLIANCE—Mr. Williamson had all the pertinent records as required by
the rule. The facility appears compliant with the following: uses ID-3D cyclones; rain caps are
removed; auger and dump area has wet suppression;gin yard and process areas are cleaned
Daily; there are two 10 MPH speed limit signs; haul trucks are covered; initial baseline study
was conducted S November 2002 by Rafe Dixon, beginning of season baseline study was done on
3 October 2022 by Mr. Rafe Dixon; static pressure checks are performed every 30 days by Mr.
Dixon; daily inspections for structural integrity are performed and documented; and record
retention requirements were being followed. CY2021 Annual Report was received at FRO on 4
February 2022 and appeared in compliance. The facility ginned 20,607 bales in CY2021, well
below the 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.
L PROHIBITION OF ODOROUS EMISSIONS—
VII. 15A NCAC 2D .1806 CONTROL AND PR O
Facility shall prevent odorous emissions from the facility from causing or contributing to
objectionable odors beyond the facility's boundary.
APPEARED IN COMPLIANCE— We did not detect any objectionable odors beyond the facility's
boundaries. Mr. Williamson stated that he has not received any odor complaints, and no odor
complaints have been received by FRO.
VIII. 112r STATUS
This facility does not store any of the listed chemicals above threshold quantities and is not required
to maintain a written Risk Management Plan (RMP).
IX. NON-COMPLIANCE HISTORY SINCE 2010
24 April 2018—NOD for late annual report.
X.

XI. CONCLUSIONS AND RECOMMENDATIONS
Piedmont Cotton, Inc. appeared to be operating IN COMPLIANCE with applicable air regulations
at the time of inspection on 1 December 2022. Based on the number of bales produced in 2021, and
their projected number of bales to be ginned in 2022,the facility still qualifies for registration.
PINK SHEET NOTES
None.
/wmt