AQ_F_0400044_20211104_CMPL_CAV-Rpt

NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY Piedmont Cotton Inc
NC Facility ID 0400044
Compliance Assurance Visit Report County/FIPS:Anson/007
Date: 11/05/2021
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,Jr. Robert Williamson,Jr.
Vice President President Vice President
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 11/04/2021
Inspector's Name Mike Thomas
Inspector's Signature: Operating Status Operating
Compliance Status Compliance Assurance Visit
'I Action Code FCE
Date of Signature: Inspection Result Compliance
Total Actual emissions in TONSIYEAR:
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

1) Location/Directions:
From FRO,take Hwy 401 South to Wagram. Turn right.onto Old Wire Road(Hwy144)and go— 11 1/2
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—1/2 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.
2) 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.
3) Facility Process and 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 1D-31).Proper static pressure readings and visible emission observations
are used to maintain compliance with 2D.0542 regulations.
4) Emission Sources:
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Cotton Ginning Operations with maximum rated gin stand Cyclones '
Capacity greater than or equal to 20 bales per hour
5) Opening Conference:
On 4 November 2021,1 Mike Thomas and Mike Turner,both of FRO DAQ,conducted a compliance
assurance visit of the Piedmont Cotton Inc.,facility. We met with Mr.Robert Williamson Jr.,manager
of the facility.We discussed the following:
a) Mr. Williamson verified that the FACFINDER information was correct and current.
b) We examined the logbook that Mr. Williamson maintains,which is kept in the office in the
ginning building.Daily entries for this season began on 6 October 2021 when the gin started
operating this season. The facility has contracted with Rafe Dixon to manage the static pressure
checks. Mr. Dixon comes by monthly to test. The 2021 baseline was conducted on 9 October
2021. The logbook contained entries for the previous seasons as well.
c) Mr.Williamson stated that they expect to gin approximately 25,000 bales. He anticipates
finishing this season around the middle of January.

d)Production:
Year Number of Bales
2020 6,381
2019 20,136
2018 1503
2017 125126
2016 117200
2015 10,876
2014 125901
2013 6,290
6) Compliance Assurance Summary:
Mr. Williamson led us on a tour of the gin house which was running when we arrived but had
stopped before our facility tour due to a small fire in the battery condenser. We observed the
cyclones. All were in good shape and showed no indications of excess emissions.V.E. ranged from
0%to 10%. The trash collection area was relatively clean. I did not observe any indications of
excess emissions from the cyclone associated with the trash collection or the collection bin.
7) Applicable Air Quality Regulations:
a) Visible Emissions Control Requirement: (15A NCAC 2D .0521)Visible emissions from the
emission sources shall not exceed 20% opacity.
APPEARED IN COMPLIANCE—V.E.ranged from 0%to 10%during this visit.
b) Excess Emissions Notification Requirements: (15A NCAC 2D .0535)-The Registrant must report
excess emissions of any regulated pollutant lasting more than four(4)hours, and that results from a
malfunction,to the Division of Air Quality by 9 am of the next working day.
APPEARED IN COMPLIANCE: Mr. Williamson stated that there have been no excessive
emissions or malfunctions that would have required reporting.
c) Fugitive Dust Control Requirement: (15A NCAC 2D .0540)-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(it had rained in the area earlier in the morning). Mr.Williamson stated
that he has not received any dust complaints at the facility and FRO has not received any dust
complaints regarding this facility.
d) Control of Particulate Emissions from Cotton Ginning Operations: (15A NCAC 2D .05.42)-
For gins rated at>20 bales/hour,the Permittee shall comply with 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 done on 9 October 2021 by Mr.Rafe Dixon, static
pressure checks are performed every 30 days, daily inspections for structural integrity are
performed and documented,and record retention requirements were being followed.

C,Y2020 Annual Report was received at FRO on 24 February 2021 and appeared in compliance.
6,381 bales were ginned,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.
2D .1806 Control and Prohibition of Odorous Emissions—Facility shall prevent odorous emissions
from the facility from causing or contributing to objectionable odors beyond the facility's boundary
APPEARED IN COMPLIANCE—I did not detect any objectionable odors beyond the facility's
boundaries. Mr. Williamson stated that he has not received any complaints related to odor.No odor
complaints.have been received by FRO.
8) 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).
9) Non-compliance History Since 2010:
None
10) Comments and Compliance Statement:
Piedmont Cotton,Inc.appeared to be IN COMPLIANCE with the applicable air quality rules and
regulations on 4 November 2021.Based on the projected number of bales to be ginned,the facility
still qualifies for registration.
Pink Sheet: no comments
/mst