HomeMy WebLinkAboutAQ_F_0400044_20191118_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: 11/20/2019
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 SIl'
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: -
f�'�]I/ Inspection Date 11/18/2019
(� f Inspector's Name Jeffrey Nelson
Inspector's Signature: GI d U Operating Status Operating
Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: 1/� Za Z On-Site 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(in pounds)
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 '/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— %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 1D-31).Proper static pressure readings and visible emission observations are used to maintain
compliance with 2D.0542 regulations.
4)Permitted Sources:
11
gk,
10.
Cotton Ginning Operations with maximum rated gin stand clones
Capacity greater than or equal to 20 bales per hour
5) Opening Conference:
On 18 November 2019,I Jeff Nelson and Mike Thomas of FRO DAQ, conducted a compliance
assistance 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)Piedmont Cotton Inc., began ginning on 30 September 2019. The facility has operated steadily since
the season began. The production rate of this gin is limited to 30 bales an hour as that is the maximum
rate of the press,however,according to Mr. Williamson 27 bales per hour is what he typically
averages. All three gin stands feed the one baler at approximately the same rate, simultaneously. Mr.
Williamson stated that production would be substantially higher than average due to the high amounts
of cotton crop yield this year.
c)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 30 September 2019 when the gin started operating this
season.Mr. Williamson conducts the daily inspections and air flow checks himself. The logbook
contained entries for the previous seasons as well.
The monthly inspection section of the logbook contained this season's baseline information.The
baseline study was conducted on 23 September 2019 by an outside contractor,Mr.Rafe Dixon.Values
for inlet velocity, static pressure, and pressure drop were documented in the report provided by Mr.
Dixon. Entries for monthly inspections and flow and pressure readings were also documented. Mr.
Williamson conducts the monthly inspections.No documented entries were out of the indicated
ranges;therefore,no corrective actions were required or documented.
d)Production:
Year Number of Bales
2018 15,063
2017 12,126
2016 11,200
2015 10,876
2014 12,901
2013 6,290
6) Inspection Summary:
Mr. Williamson led me on a tour of the facility starting with the cyclones behind the gin building.
The cyclones appeared to be in good shape. All of the external duct work appeared to be in good
shape as well. It was raining during the time of the inspection but the V.E.at the cyclones was 10%.
I observed no problems and the area around the cyclones was very clean as were the grounds in
general.
I observed the waste baling system. The baler is located below the cyclones. Waste drops from the
bottom of the cyclones into a bin and is conveyed into the baler. The baler compresses the waste
into a dense block roughly the size of a bale of hay. Mr. Williams still maintains the old waste bin
and can use it to stock pile material in the event that the baler breaks down.
We then toured the inside of the ginning building. All three of the gin stands were operating during
the inspection. The inside of the facility was very clean. I observed no problems.
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 exceedances of
emissions 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: I observed no issues with fugitive dust at the facility or 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.
d) Control of Particulate Emissions from Cotton Ginning Operations: (15A NCAC 2D .0542)-For gins
rated at>20 balesihour,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
23 September 2019 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 26 March 2018 and appeared in compliance.
15,063 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
nextseason.
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 18 November 2019.
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