AQ_F_0400044_20181120_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: 11/20/2018
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 Classification 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,Sr. Robert Williamson,Jr.
Vice President President Vice President
[phone] [phone] [phone]
Compliance Data
Comments:
Y�(✓ Inspection Date 11/20/2018
Inspector's Name Mike Thomas
Inspector's Signature: Operating Status Operating
/ LigaZe4
Compliance Code Compliance-inspection
Action Code FCE
Date of On-Site Inspection Result Compliance
//-Zo
al �g
Total Actu emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2011 20.31 6.94 ---
2006 23.98 8.19 ---
Highest HAP Emitted(in ounds)
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— �/2 mile until Cotton Street.Tom 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-3D.Proper static pressure readings and visible emission observations are used to maintain
compliance with 2D.0542 regulations.
4)Permitted Sources:
Emission's Equipment Table
Emissions Sources Control Devices
Cotton Ginning Operations with maximum rated gin stand Cyclones
Capacity greater than or equal to 20 bales per hour
5) Opening Conference:
On 20 November 2018, I 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 8 October 2018.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 a little lower than average due to the high amounts of rain
during the harvesting season.
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 8 October 2018 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 2 October 2018 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
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. V.E. at the cyclones was 10%. I observed no problems. 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 TO BE IN COMPLIANCE:Mr.Williamson stated that there have been no
exceedances of emissions that would have required reporting.
c) Fujzitive 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 TO BE 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.
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 TO BE 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 2
October 2017 by Mr.Raif 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.
CY2017 Annual Report was received at FRO on 26 March 2018 and appeared in compliance
because 12,126 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.
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 20 November 2018.
Pink Sheet: no comments
/mst