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HomeMy WebLinkAboutAQ_F_0700137_20191209_CMPL_InspRpt (4) NORTH CAROLINA DIVISION OF Washington Regional Office AIR QUALITY Coastal Carolina Gin,LLC-Pantego NC Facility ID 0700137 Inspection Report County/FIPS:Beaufort/013 Date: 12/20/2019 Facility Data Permit Data Coastal Carolina Gin,LLC-Pantego Permit 08287/G06 4851 Terra Ceia Road Issued 6/8/2017 Pantego,NC 27860 Expires 4/30/2025 Lat: 35d 35.3520m Long: 76d 44.3180m Class/Status Small SIC: 0724/Cotton Ginning Permit Status Active NAICS: 115111 /Cotton Ginning Current Permit Application(s)None Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact SIP John VanStaalduinen Todd Waters Todd Waters Warehouse Manager General Manager General Manager (252)943-6990 (252)943-6990 (252)943-6990 Compliance Data Comments: The facility appeared to operate in compliance with all applicable air quality regulations and permit conditions at the time of inspection. Inspection Date 12/09/2019 Inspector's Name Samantha Mellott Inspector's Signature:,,' Operating Status Operating Compliance Code Compliance-inspection Action Code FCE Date of Signature: 12/20/2019 On-Site Inspection Result Compliance Total Actual emissions in TONSIYEAR: TSP S02 NOX VOC CO PM10 *HAP 2016 0.0000 --- --- --- --- 0.0000 --- 2011 60.15 --- --- --- --- 23.28 --- Highest HAP Emitted(in pounds) Five Year Violation History:None Performed Stack Tests since last FCE:None Location:From WaRO take Hwy 264 E towards Pantego.At the junction of SR1616 and Hwy 264 turn left on Terra Ceia(SR1616) at the water tower and travel approximately five miles. The facility will be located on your right at a road junction. Facility Summary: This facility is a cotton ginning operation that produces raw cotton for industrial use.This gin has a rated capacity of 38 bales per hour. Facility Safety: Required PPE:hardhat, safety glasses,earplugs,and safety-toe shoes;No climbing is required Permitted Sources: Emission Source ID Emission Source Description Control System ID Control System Description CG-1 Emission sources and air filtration CS-1 Cyclones(1D-3D and 2D-2D systems(s)utilized in cotton cyclones typical per ginning process,(Standard 2D.0542) Industrial 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] Inspection Observations/Comments: On December 9,2019 at 11:00 a compliance inspection was conducted by myself, Samantha Mellott,Environmental Specialist with the assistance of Mr.Todd Waters,General Manager. Mr.Waters stated that there have been no changes at the facility. Operation for the 2019 season began October 1 and ended December 6,2019.1 was provided a logbook that contained a copy of the facilities' air permit,records of daily equipment inspections,and records of monthly static pressure checks(performed October 1,November 1,and December 1,2019). Seasonal startup measurements were taken October 1,2019 and were within range. The facility was not operating at the time of inspection and cleanup for the end of the season was well under way. All equipment and duct work appeared to be in good repair.I did not observe any odors or fugitive dust. 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 operating at the time of inspection.No complaints regarding visible emissions have been received since the time of 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 inspection. 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 time of last inspection.The facility utilizes irrigation lines on the lot when it gets too dusty and IOmph signs are posted.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 odors were detected during the inspection and no complaints regarding odors have been received since the 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 1D-31)or 2D-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 all 1D-3D cyclones that were not operating at the time of inspection.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. This logbook can be found in the plant manager's office 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 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 composting system: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.Material is kept on site and composted when the dump area is cleaned. 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. 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 irrigation lines 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 assumed Monitorine-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 most recent baseline study was conducted September 29,2005 by Ramsey Air Management. 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. This logbook can be found in the plant manager's office and records review indicates that static pressure is measured monthly. 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. Seasonal startup measurements were taken October 11,2019 and were 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. The most recent baseline study was conducted September 29,2005 by Ramsey Air Management and no system changes have occurred since. 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 can be found in the plant manager's office 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 2019 season was conducted December 6,2019. 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 can be found in the plant manager's office 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 2018 yearly report was received by this office February 22,2019 and indicated that 41,349 bales of cotton were ginned. Compliance is indicated 2Q.0310-Permitting of Numerous Similar Facilities This rule allows for the issuance of general permits.No unique differences or analyses can be required for permits issued under this rule. This facility has no unique differences. Compliance is indicated 2Q.0806-Cotton Gins 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 2018 yearly report was received by this office February 22,2019 and indicated that 41,349 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. Compliance History:No Notices of Deficiency(NODS)or Violations(NOVs)have been issued in the last 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 inspection.