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HomeMy WebLinkAboutAQ_F_0800061_20220105_CMPL_CAV-Rpt NORTH CAROLINA DIVISION OF Washington Regional Office AIR QUALITY Woodville Gin,LLC. NC Facility ID 0800061 Inspection Report County/FIPS:Bertie/015 Date: 3/25/22 Facility Data Permit Data Woodville Gin,LLC. Permit n/a 408 South Main Street Issued n/a Lewiston Woodville,NC 27849 Expires n/a Lat: 36d 7.1760m Long: 77d 10.7480m Class/Status Registered SIC: 0724/Cotton Ginning Permit Status Inactive NAILS: 115111 /Cotton Ginning Current Permit Application(s)None Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact SIP Raggs Rascoe Raggs Rascoe Raggs Rascoe Manager Manager Manager (252)348-2565 (252)348-2565 (252)348-2565 Compliance Data Comments: The facility appeared to operate in compliance with all applicable air quality regulations and permit conditions at the time of the inspection. Inspection Date 1/5/2022 Inspector's Name Andrew Langley Inspector's Signature:AvOrew l_awrgLeU Operating Status Operating Compliance Code Compliance-inspection Action Code CAV Date of Signature: 3/25/22 On-Site Inspection Result Compliance Total Actual emissions in TONSIYEAR: TSP S02 NOX VOC CO PM10 *HAP 2016 20.97 --- --- --- --- 7.17 --- 2011 35.82 --- --- --- --- 12.24 --- Highest HAP Emitted inpounds) �LiveYear Violation History:None Performed Stack Tests since last FCE:None Location: Take US 17 N to Windsor then NC 308 W to Lewiston. In Lewiston,turn left at the traffic light. Turn left at the old Woodville Supply general store and the gin is on the left in approximately 500 yards. Facility Summary: This gin has two gin stands and a rated capacity of 32 cotton bales per hour. Facility Safety:Recommended PPE:hardhat, safety vest, safety glasses,earplugs,and steel-toe shoes Sources: Emission Source Emission Source Description Control Control System ID System ID Description ES-CG-I Emission sources and air filtration system(s) CS-1 Cyclones(1D-31)and 2D- utilized in cotton ginning process,(Standard 2D cyclones typical per Industrial Classification Code(SIC)0724) [max 2D.0542) rated gin stand capacity>20 bales/hr regardless of the number of gin stands and/or modified or new facilities constructed after July 1,2002] Observations/Comments: On January 5,2022 at 10:00 a.m. I conducted a compliance inspection at Woodville Gin,LLC,with the assistance of Ms.Tonya Baker/office secretary.The facility was not in operation at the time of the inspection.Ms.Baker told me that the facility started up on 10/14/21 and finished ginning on 12/23/21 with a total of 37,377 bales being ginned.Ms.Baker also stated that their seasonal startup readings and monthly measurements were performed by Todd Ramsey with Ramsey Manufacturing and that their daily structural integrity/maintenance checks are performed by the facility itself.Ms.Baker informed me that when they are in operation that the gin yard is cleaned daily and that they use a water truck to help control any dust or odors that may be coming from their facility. I did not observe any fugitive dust or objectionable odors at the facility during my inspection. Regulatory Review: 2D.0521 - Control of Visible Emissions Visible emissions from the permitted sources shall not be more than 20%opacity when averaged over a six-minute period. The facility was not in operation at the time of this inspection.No complaints or issues have been noted regarding visible emissions since the last inspection. Compliance is indicated 2D.0535-Excess Emissions reporting and Malfunctions There were no indications of equipment malfunctions that would result in excessive emissions requiring more than four hours to repair.No such reports have been submitted since the time of last visit. Compliance is indicated 2D.0540-Fugitive Dust Control The permittee shall not cause or allow fugitive dust emissions to cause or contribute to substantive complaints or excess visible emissions beyond the property boundary. No fugitive dust emissions were observed and no complaints regarding fugitive dust have been received since the last inspection.The facility utilizes a water truck as needed to reduce fugitive dust emissions. Compliance is indicated 2D.1806- Control and Prohibition of Odorous Emissions The permittee shall not operate this facility without implementing management practices or installing and operating odor control equipment sufficient to prevent odorous emissions from causing or contributing to objectionable odors beyond this facility's boundary. No objectionable odors or fugitive dust were detected during the inspection and no complaints regarding such have been received since their last inspection. Compliance is indicated 2D.0542- Control of Particulate Emissions from Cotton Ginning Operations Emission Control Requirements-This permittee shall control all high pressure exhausts and lint cleaner exhausts with an emission control system that includes one or more properly sized 113-313 or 213-2D cyclones to achieve 95%efficiency.All low pressure exhausts,except lint cleaner exhausts,shall be controlled by an emission control system that includes one or more properly sized 1D- 3D or 2D-213 cyclones to achieve 90%efficiency. The facility is equipped with the correct cyclones but were not in operation on this date.Records of regular cyclone inspections and maintenance were provided and they appear to be in good repair. Compliance is indicated Rain cans-Exhausts from emission points or control devices shall not be equipped with rain caps or other devices that deflect emissions downward or outward. No rain caps are installed. Compliance is indicated Operation and Maintenance-The permittee shall establish and keep record of,based on manufacturer recommendations,an inspection and maintenance schedule for the control devices,other emission processing equipment,and monitoring devices that are used pursuant to 15A NCAC 2D.0542. The facility logbook is kept on site and records review indicates that all control devices are inspected daily and serviced as needed. Compliance is indicated Fugitive Emissions-The owner or operator shall minimize fugitive emissions from cotton ginning operations as follows: i. Trash stacker:The operator of a trash stacker shall install,maintain,and operate as a minimum a three sided enclosure with a roof whose sides are high enough above the opening of the dumping device to C:\Users\Owner\Documents\0800061_20220105_cay.docx) Page 2 prevent wind from dispersing dust or debris. In lieu of this the operator may install,maintain,and operate a device to provide wet suppression at the dump area of the trash cyclone and minimize free fall distance of waste material exiting the trash cyclone. Wet suppression is used and free fall distance is minimized. Compliance is indicated ii. Trash stacker/Trash compostingsystem: The operator of a trash stacker/trash composting system shall install,maintain,and operate a wet suppression system providing dust suppression in the auger box assembly and at the dump area of the trash stacker system.The operator shall keep the trash material wet and compost it in place until the material is removed from the dump area for additional composting or disposal. Wet suppression is used and free fall distance is minimized.Trash material is kept on site and used as fertilizer on fields once the dump area is cleared. Compliance is indicated iii. Gin yard:The operator shall clean and dispose of accumulations of trash or lint on the non-storage areas of the gin yard daily. The gin yard is cleaned daily and no trash or lint was observed around the facility. Compliance is indicated iv. Traffic areas: The operator shall clean paved roadways,parking,and other traffic areas at the facility as necessary to prevent re-entrainment of dust or debris. The operator shall treat unpaved roadways, parking,and other traffic areas at the facility with wet or chemical dust suppressant as necessary to prevent dust from leaving the facility's property.In addition,the operator shall install and maintain signs limiting vehicle speed to 10 miles per hour where chemical suppression is used and to 15 miles per hour where wet suppression is used. Dust was not observed on the yard or traffic areas at the time of inspection.The facility utilizes a water truck on the lot when it gets too dusty and 1 Omph signs are posted. Compliance is indicated V. Transport of trash material: The operator shall ensure that all trucks transporting gin trash material are covered and that the trucks are cleaned of over-spill material before leaving the trash hopper dump area.The dump area shall be cleaned daily. I did not observe any trucks transporting gin trash material during the inspection.The dump area and yard were clean and no complaints have been received by this office. Compliance is indicated Monitoring-The owner or operator of each ginning operation shall install,maintain,and calibrate monitoring devices that measure pressure,rates of flow,and other operating conditions necessary to determine if the control devices are functioning properly. i. Baseline studies: The operator of each gin shall ensure air flows(air velocities)of the entire dust collection system,without cotton being processed,are within the design range for each collection device.For 1D-3D cyclones the design range is 2800 to 3600 feet per minute.During the initial and all additional baseline studies,the operator shall measure or determine according to the methods and record in a logbook:the calculated inlet velocity for each control device and the pressure drop across each control device(this will be the static pressure provided that the control device releases to the atmosphere). The seasonal startup measurements as well as their monthly measurements were performed by Ramsey Manufacturing. The logbook indicates that flows are within the design range. Compliance is indicated ii. Monthly static pressure checks and corrective action: On a monthly basis following the initial baseline study or new season flow range verification measurements,the operator shall measure and record the static pressure at each port measured in the baseline study.Measurements shall be made using a manometer,a magnahelic gauge,or other approved device.A deviation of 20%or more from the baseline study indicates the need for corrective action.Any corrective actions shall be recorded.If a corrective action will take more than 48 hours to complete the operator shall notify the regional supervisor no later than the end of the day such static pressure is measured. C:\Users\Owner\Documents\0800061_20220105_cay.docx) Page 3 This logbook is kept on site and records review indicates that static pressure is measured monthly at minimum. Compliance is indicated iii. Seasonal startup flow range verification measurement: The facility shall perform air flow verification measurements without cotton being processed no later than the first week of operation of each new season.This measurement should be recorded and will serve as the first monthly measurement of the new season.A deviation of 20%or more from the baseline study shall be cause for corrective action.If any corrective action will take more than 48 hours to complete the operator shall notify the regional supervisor no later than the end of the day the deviation was measured. Ramsey Air performed the baseline study and monthly measurements and records review indicates that subsequent checks have been within range. Compliance is indicated iv. New baseline studies:If changes are made to any portion of the dust control system a new baseline study shall be conducted and recorded.Thereafter all monthly static pressure readings for that portion of the system shall be compared to the new values. No system changes have occurred since the previous inspection. Compliance is indicated V. Daily inspections for structural integrity:During the ginning season the operator shall perform and record daily inspections for structural integrity of the control devices and other emission processing systems.These inspections shall ensure that the control devices and emission processing systems conform to normal and proper operation of the gin.If a problem is found corrective action shall be taken and recorded. This logbook is kept on site and records review indicates that all control devices are inspected daily and serviced as needed. Compliance is indicated vi. At the conclusion of the ginning season the operator shall conduct an inspection of the facility to identify all scheduled maintenance activities and repairs needed relating to the maintenance and proper operation of the air pollution control devices for the next season.Any deficiencies identified through the inspection shall be corrected before beginning operation of the gin for the next season. The final inspection for the 2021 season was conducted and a copy was mailed 2/25/22 as per Raggs Rascoe/Gin Manager. Compliance is indicated Recordkeeping-The operator shall establish and maintain a logbook documenting the following items: i. Results of the baseline study ii. Results of monthly static pressure checks and any corrective action taken iii. Results of season startup flow range verification measurements and any corrective action taken iv. Results of new baseline studies V. Observations from daily inspections of the facility and any resulting corrective actions taken vi. A copy of the manufacturer's specifications for each type of control device installed The logbook shall be maintained on site and made available to the DAQ representative upon request. This logbook is kept on site and records review indicates that it contains all required information. Compliance is indicated Reporting-The operator shall submit by March 1 of each year a report containing the following: i. The name and location of the cotton gin ii. The number of bales of cotton produced during the previous ginning season iii. A maintenance and repair schedule based on inspection of the facility at the conclusion of the previous cotton ginning season iv. Signature of the appropriate official certifying as to the truth and accuracy of the report The 2021 yearly report was received by this office 3/10/22,but as noted previously by Mr.Rascoe,the forms were actually mailed on 2/25/22 and indicated that 37,377 bales of cotton were ginned. Compliance is indicated 2Q.0806- Cotton Gins C:\Users\Owner\Documents\0800061_20220105_cay.docx) Page 4 This rule allows gins to avoid Title V status by limiting production to 167,000 bales of cotton per year(bale defined as weighing no more than 500 pounds).The facility shall provide by March 1 of every year the name and location of its cotton gin and the number of bales of cotton produced during that season. The 2021 yearly report was received by this office 3/10/22 but as noted previously the information was actually mailed on 2/25/22 and indicated that 37,377 bales of cotton were ginned. Compliance is indicated 112(r)Applicability-This facility does not handle,store,or use any 112R pollutants in sufficient quantity to be subject to this rule. Five Year Compliance History: The facility has not received a Notice of Deficiency(NOD)or Notice of Violation(NOV)in the past five years. Conclusions,Comments,and Recommendations:The facility appeared to operate in compliance with all applicable air quality regulations and permit conditions at the time of the inspection. C:\Users\Owner\Documents\0800061_20220105_cay.docx) Page 5