AQ_F_0900066_20171212_CMPL_NOV

ROY COOPER
Governor
MICHAEL S. REGAN
Secretory
MICHAEL A. ABRACZINSKAS
Air Quality Director
ENVIRONMENTAL QUALITY
12 December 2017
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. John Sargent
General Manager- South Central Region
Murphy-Brown, LLC
PO Box 759
Rose Hill,NC 28458
SUBJECT:Notice of Violation
15A NCAC 02D .0611 —Fabric Filter Requirement
15A NCAC 02D .1111 —Prepared Feeds Manufacturing NESHAP (GACT 7D)
15A NCAC 02Q .0315— Synthetic Minor Limitation to Avoid Title V
Murphy-Brown, LLC—Bladenboro Feedmill Permit No. 08155RI O
Bladenboro,NC, Bladen CountyFacility ID: 09-00066 Fee Class: Synthetic Minor
Dear Mr. Sargent:
On 15 November 2017, Mr. Stephen Allen and Mrs. Heather Carter, with the Fayetteville
Regional Office of the Division of Air Quality (FRO DAQ), met with Mr. Mitchell Batts,
Feedmill Manager, to conduct a full air quality compliance inspection of Murphy-Brown, LLC —
Bladenboro Feedmill, in Bladenboro, Bladen County, NC. During this inspection, Mr. Allen and
Mrs. Carter noted that records were not readily accessible and that the general knowledge of
required records was lacking. Additionally, the housekeeping records, required by the Prepared
Feeds Manufacturing NESHAP (GACT 7D), were deficient in that some records were simply
assignments and not records of completion and the records were spread among so many different
pieces of paper it was impossible to determine if the monthly requirement had been met for all
subject areas of the mill. The availability of records, especially for the bagfilters and cyclones,
has been an issue that FRO DAQ has attempted to work with the facility on for several years.
The following violations of the current air permit Specific Limitations and Conditions were
found during this inspection:
1. 15A NCAC 2D .0611, Fabric Filter Requirements —Permit Condition A.10.a requires
the Permittee to perform, at a minimum, an annual (for each 12-month period
following the initial inspection) internal inspection of each bagfilter system.
According to facility records, bagfilter CD-218 had missed the annual inspection
State of North Carolina I Environmental Quality I Air Quality
Fayetteville Regional Office 1 225 Green Street.Suite 7141 Fayetteville,North Carolina 28301
910 433 3300 T 1 910 485 7467 F

Murphy-Brown, LLC—Bladenboro Feedmill
12 December 2017
Page 2
cycle at the time of inspection. Additionally, the facility's inspection records
provided during the previous inspection, on 27 April 2017, do not match with the
records provided during this inspection, indicating an underlying issue with
recordkeeping.
2. 15A NCAC 2D .1111, Prepared Feeds Manufacturing (GACT 7D) — Permit
Condition A.12.(D)(i) requires the Permittee to perform quarterly inspections of each
cyclone for corrosion, erosion, or any other damage that could result in air in-leakage,
and record results of any maintenance or repairs in a logbook to be maintained on
site. Mr. Batts found records for quarterly cyclone inspections for Q1 and Q4, but
inspection records for Q2 and Q3 were not available. Following the onsite
inspection, Mr. Batts sent an email with work orders, dated 5-1-17 and 7-5-17, that
indicated something had been done for some of the cyclones. However, these records
were not specific to the individual cyclones, they were incomplete as they did not
indicate the type of inspection or work that had been performed, and the records
provided, that were two pages in length each, appeared to be mismatched and not a
contiguous record. Be advised that the inspection and maintenance requirement is for
each cyclone.
3. 15A NCAC 02Q .0315, Limitation to Avoid Title V — Permit Condition A.15.a.iii
requires the Permittee to limit throughput of the bagging operation (ID No. ES-022)
to not exceed 50,000 tons per consecutive 12-month period. During the inspection,
Mr. Batts accessed facility monthly records for the bagging operation throughput and
determined that the facility bagged 51,656 tons from October 2016-September 2017,
thus exceeding the permitted limit. Following the onsite inspection, Mr. Batts sent an
email with a production total table that had a different total of 50,002 tons for the
bagging operation for this same time period, which still exceeds the permit limit. It
should also be noted that during the previous inspection, in April 2017, the facility
was close to the permit limit and the DAQ inspector suggested to Mr. Batts to keep a
rolling total for each month to avoid exceeding the limit. While it does not appear
that the facility exceeded the Title V actual emissions threshold, the facility did
exceed the permit limit.
This letter represents a Notice of Violation for the above-cited violations. These
violations and any future violation of an air quality regulation are subject to the assessment of
civil penalties per North Carolina General Statute 143-215.114A. In addition, each day of
continuing violation after written notification from the Division of Air Quality shall be
considered a separate offense.
We are concerned about what appears to be a pattern of poor recordkeeping and tracking
for this facility. Please provide to this office as soon as possible, but no later than
30 December 2017, a written response detailing: 1) the reasons for violating the above-
mentioned permit requirements, 2) the steps that you plan to take or have taken to return to
compliance, and 3) any additional information or description of any mitigating circumstances in

Murphy-Brown, LLC—Bladenboro Feedmill
12 December 2017
Page 3
reference to the violations. Please note that violations of the Prepared Feeds Manufacturing
NESHAP (GACT 7D) must be reported in the facility's Annual Compliance Certification(ACC)
report for 2017, which must be postmarked for submittal to the FRO DAQ on or before 1 March
2018.
Additionally, the Division strongly recommends that you carefully examine your current
permit stipulations. If you have any questions regarding these violations, please call Stephen
Allen, Environmental Specialist, or Heather Carter, Compliance Coordinator, at 910-433-3300.
Sincerely
gory Card
or W. Reeves
g Y
Acting Regional Supervisor
NCDEQ, Division of Air Quality
GWR\sca
cc: FRO Facility Files