HomeMy WebLinkAboutAQ_F_0400044_20201209_CMPL_CAV-Rpt NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY Piedmont Cotton Inc
NC Facility ID 0400044
Compliance Assurance Visit County/FIPS:Anson/007
Date: 12/21/2020
Facility Data Permit Data
Piedmont Cotton hic 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
Faciliy Contact Authorized Contact Technical Contact SIP
Robert Williamson,Jr. Robert Williamson, Sr. Robert Williamson,Jr.
Vice.President President Vice President
(704)272-7580 (704)272-7580 (704)272-7580
Compliance Data
Comments:
/ Inspection Date 12/09/2020
Inspector's Name Mike Thomas
Inspector's Signature: Operating Status Operating
� ` Compliance Code Compliance Assurance Visit
�L Action Code FCE
Date of Signature: On-Site Inspection Result Compliance
i2 .41-20
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2011 20.31 --- --- --- --- 6.94 ---
2006 23.98 --- --- --- --- 8.19 ---
* Hi est 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 '/s 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 comer). Turn left and go—'/z 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.Each of these cyclones are
`,TD-3,D.Proper static pressure readings and visible emission observations are used to maintain
compliance with 2D.0542 regulations.
4) Emission Sources:
Cotton Ginning Operations with maximum rated gin stand Cyclones
Capacity greater than or equal to 20 bales per hour
5) Opening Conference:
On 9 December 2020,Mike Thomas of FRO DAQ, conducted a compliance assurance visit of the
Piedmont Cotton Inc.,facility. I 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) I examined the logbook that Mr. Williamson maintains,which is kept in the office, in the ginning
building.Daily entries for this season began on 24 October 2020 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 2020 baseline was conducted on 12 October 2020. The logbook
contained entries for the previous seasons as well.
c) Mr. Williamson stated that they expect to gin approximately 6000 bales. He anticipates finishing
this season around the middle of January.
d)Production:
Year Number of Bales
2019 20,136
2018 15,063
2017 12,126
2016 11,200
2015 10,876
2014 12,901
2013 6,290
6) Compliance Assurance Summary:
Due to Covid-19 restrictions,I did not tour the gin floor. I made observations through the large office
window that looks into the gin area. I did not observe any issues in this area. I observed the cyclones.
All were in good shape and showed no indications of excess emissions. V.E.was approximately 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.was 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 result 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) Fuaitive 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 COMPLUNCE:I observed no issues with fugitive dust beyond the boundaries of
the property. 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 .0542)-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 1D-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 12 October 2020
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.
CY2018 Annual Report was received at FRO on 13 February 2020 and appeared in compliance.
20,136 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 9 December 2020.Based on the projected number of bales to be ginned,the facility still
qualifies for registration,
Pink Sheet: no comments
/mst