AQ_F_0900066_20171115_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY Murphy-Brown,LLC-Bladenboro Feed Mill
NC Facility ID 0900066
Inspection Report County/FIPS:Bladen/017
Date: 11/27/2017
Facility Data Permit Data
Murphy-Brown,LLC-Bladenboro Feed Mill Permit 08155/R10
255 Bryant Swamp Road Issued 3/4/2015
' Bladenboro,NC 28320 Expires 2/28/2023
Lat: 34d 33.1310m Long: 78d 49.7910m Classification Synthetic Minor
SIC: 2048/Prepared Feeds Nec Permit Status Active
NAILS: 311119/Other Animal Food Manufacturing Current Permit Application(s)None
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Contact Data Program Applicability
i Facility Contact Authorized Contact Technical Contact SIP
f Mitchell Batts John Sargent Katie Elmer MACT Part 63: Subpart 7D,Subpart ZZZZ
4 NSPS: Subpart Dc
Feedmill Manager General Manager- South Environmental Engineer
[phone] Central Region [phone]
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[phone]
Compliance Data
E Comments:
Inspection Date 11/15/2017
Inspector's Name Stephen Allen
Inspector's Signature: "" (' c. Operating Status Operating
r Cl Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: l 1/ 2 On-Site Inspection Result Violation
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Total Actual emissions in TONSIYEAR:
E TSP S02 NOX VOC CO PM10 *HAP
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2013 62.17 0.0300 4.88 0.2700 4.10 29.73 175.00
2008 60.37 0.0400 4.73 0.2600 3.94 29.14 168.00
*Highest HAP Emitted inpounds)
Five Year Violation History:
Date Letter Type Rule Violated Violation Resolution Date
k 08/18/2014 NOV 21) .0524 New Source Performance Standards 08/28/2014
Performed Stack Tests since last FCE:None
E
Date Test Results Test Method(s) Source(s)Tested
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I. DIRECTIONS:
Murphy-Brown, LLC —Bladenboro Feed Mill facility is located on Bryant Swamp Road in Bladenboro,
Bladen County. From FRO, take US I-95 South to Lumberton. Take exit #20 (Hwy 211) to
Lumberton/Red Springs, turning left onto Hwy 211 (Roberts Ave). Travel 3.3 miles and turn left to stay
on Hwy 211, toward Bladenboro. Travel approx. 8 miles to NC Hwy 211 Business. Take NC Hwy 211 1
Business toward Bladenboro. Travel—1.5 miles to Bryant Swamp Road and turn right. The facility is 0.2 j
miles on the left.
H. SAFETY CONCERNS:
1
Hard hat, safety shoes,ear plugs and safety glasses are required. Watch for truck traffic.
III. FACILITY/PROCESS DESCRIPTION:
Murphy-Brown, LLC —Bladenboro Feed Mill is an animal feed manufacturing mill. They receive corn,
soybean,grain,and by-products at two(2)truck-receiving pits where there is one(1)fabric filter installed
to control dust and one uncontrolled rail-receiving pit. All soft ingredients are transferred to the interior
structure of the mill via one of two (2) receiving systems, each of which has a bagfilter installed. Corn
and grains pass through one (1) of four(4) hammer mills (where each pair of hammer mills is controlled
by a single bagfilter) and then to their respective bins. Liquid fat is pumped directly into a bin from the
truck. Vitamins and minerals are transferred, via a pneumatic receiving system controlled by a bagfilter,
from the truck to the interior structure of the mill. Materials are then weighed(how much depends on the
feed they are making)and blended to make feed mash. The mash is then sent through one(1)of three(3)
pellet mills, and then the pellets go into one (1) of three (3) pellet coolers, controlled by three (3) high
efficiency cyclones installed in parallel on each one of the coolers. After the feed has cooled it is loaded
onto trucks and shipped to the farms. The facility has two (2)NG/No. 2 fuel oil-fired boilers, normally
operating on NG,that provide steam for the manufacturing operations.
IV. EMISSION SOURCES:
Permitted:
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Truck grain receiving pit,
Bagfilter
ES-001 and soft ingredients pit ; CD-107
Operating,brief fugitive emissions noted Ik (850 square feet of filter area)
WW Receiving turnhead negative air system Bagfilter
ES-002 Fc
D-123Operating 0%opacity � (332 square feet of filter area)
Receiving turnhead negative air system F_ Bagfilter
ES-003 i CD-124
Operating 0%opacity ! (209 square feet of filter area)
Pneumatic receiving system Bagfilter
ES-004F CD-129FNot Operating (200 square feet of filter area)
Bagfilter
Pneumatic receiving system k E
ES-005 Not Functional 4 CD-133 (200 square feet of filter area)
Removed from site
Ground grain negative air system BagfilterBagfilter
ES-009 CD-218
Operating 0%opacity (300 square feet of filter area)
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_ �j •' -v;^,ems �� ,t \\\.��x\` a � � �\ � �z
ES-016a One(1)load-out system having twenty(20)
(NESHAP) load-out bins N/A
Operating 0%opacity
Ems......... ......:.. �«..a::-.......... ......
ES-016b One(1)load-out system having twenty(20)
(NESHAP) load-out bins N/A
Operating 0%opacity
... ...... ...... ... ... ..................................................... ... .......
ES-017 Rail Car Receiving N/A
Not Operating
Truck grain receiving pit, 15,000 bushels/hr max,
ES-018 E throughput,with partially enclosed shelter N/A
17
Operating,Intermittent fugitive emissions
noted at 5-10%opacity
ES-020a Wet grain storage silo,55,000 bushels capacity N/A
i empty,not being dispensed
ES-020b Wet grain storage silo,55,000 bushels capacity N/A
empty,not being dispensed
M !MIN
Al"11
.............................................................\ ....... . ..... .. ..... ... ..... ..... .
Generator,No.2 fuel oil fired,750 KW,Onan
Model D970636382 and Serial 86930A,with
ES-016 turbocharger and low temperature aftercooler N/A
(NESHAP)
control devices.
Not Operating
..... ...... ............................................................................. ......... .... ........ .. .. ... .. .. .. ..... . .... .... .. ...... .
k ES-014 Natural gas/No.2 fuel oil-fired boiler(20.925
(NSPS) million Btu per hour maximum heat input) N/A
Operating on natural gas;0%opacity.
ES-013 Natural gas/No.2 fuel oil-fired boiler(20.925
(NSPS) million Btu per hour maximum heat input) i N/A
Operating on natural gas, 0%opacity
• \ \ \ \
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Hammer mill system(capacity: 53 tons/hour) I Airlanco Model 100AST10-II Bagfilter
ES-007a I CD-212 1
Operating;0%opacity (1,640 sq.ft.of filter area)
... .: .. .. ......... ......................-......... .
ES-007b Hammer mill system(capacity: 53 tons/hour) Airlanco Model 100AST10-II Bagfilter
CD-212
Operating;0%opacity (1,640 sq. ft.of filter area)
Hammer mill system(capacity: 53 tons/hour) Airlanco Model 100AST10-II Bagfilter
ES-008a CD-312 1 640 s ft.of filter area Operating,0%opacity ( , q. )
Hammer mill system(capacity: 53 tons/hour) Airlanco Model 100AST10-II Bagfilter
ES-008b Operating;0%opacity CD-312 (1,640 sq. ft.of filter area)
...:.............................. - .... .....:
ES-010 Pelleting system(capacity 60 tons/hour) Three(3)cyclones installed in parallel
CD-508
(NESHAP) Operating,0%opacity I (54 inches in diameter each)
..... .. �...:: _ .._. ..
ES-011 Pelleting system(capacity.60 tons/hour) Three(3)cyclones installed in parallel
(NESHAP) Operating,0%opacity CD-608 (54 inches in diameter each)
ES-012 Pelleting system(capacity: 60 tons/hour) CD-708 Three(3)cyclones installed in parallel
(NESHAP) Operating,0%opacity (54 inches in diameter each)
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ES-0157 Mixed feed turnhead negative air system 1 Bagfilter
(NESHAP) (capacity:36 tons/hour) CD-422 (209 square feet of filter area)
Operating, 0%opacity
Natural gas-fired grain dryer,47.8
ES-019 million Btu per hr maximum heat input N/A
.......... .. Not Operating ,
�..... .............................
ES-021 Grain dryer truck loadout N/A
Not Operating
ES-022 Bagging Operation N/A j
Not Operating
Insignificant:
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IES-101 -Storage Silos 2Q.0102(c)(2)(E)(i) No Yes
IES-IO2 r Storage Silos 2Q.0102(c)(2)(E)(i) No Yes
IES-103 -Storage Silos 2Q.0102(c)(2)(E)(i) No Yes
IES-104-Storage Silos 2Q.0102(c)(2)(E)(i) No Yes
IES-105a-Storage Silos 2Q.0102(c)(2)(E)(i) No Yes
IES-106-Storage Silos 2Q.0102(c)(2)(E)(i) No Yes
IES-107-Storage Silos 2Q.0102 c 2 E i No Yes
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IES-108 Storage Silos F 2Q.0102(c)(2)(E)(i) No Yes
V. INSPECTION SUMMARY: i
On 15 November 2017, Heather Carter and I, Stephen Allen of FRO DAQ, arrived at Murphy-Brown,
LLC—Bladenboro Feed Mill facility to conduct an annual compliance inspection. We met with Mitchell
Batts,Feed Mill Manager and he reviewed the FacFinder data and did not note any changes. We reviewed
the facility's records required for GACT 7D (Feed Mfg NESHAP), GACT 4Z (RICE NESHAP),
bagfilters and cyclones, and facility throughputs. Recordkeeping at the facility was still somewhat
unorganized, and records of cyclone quarterly inspection and maintenance were not readily available or
complete. The facility recently implemented a new tracking system but some of the records were missing.
Mr. Batts attributed this to turnover in the front office. Monthly totals for production were not accessible
in a format that made it easy to track bagged feed production for 12 consecutive months. After reviewing
records,Mr.Batts escorted me on a tour of the facility.The facility was receiving a load of sorghum and a
load of soybean during the inspection of the truck receiving area. Intermittent fugitive emissions were
observed at 5-10%opacity,but nothing was exceeding the property boundary. The facility was relatively
clean and I observed 0%VE from all other operating sources. The emergency generator is scheduled for
annual maintenance on 19 November 2017. Mr. Batts considered disconnecting the generator and taking
it off the permit but has decided to continue to maintain it and keep it in the permit. It will need to be -
maintained as required by NESHAP 4Z. Mr. Batts was unfamiliar with the menu screen on the generator
and was unable to find the hourly meter total on the machine. The maintenance supervisor was on
vacation and no one at the facility was familiar with the operation of the emergency generator.

VI. PERMIT STIPULATIONS:
A. A.2. Permit Renewal and Emission Inventory Requirement —entire facility subject. Permit
renewal request and emission inventory due at least 90 days prior to permit expiration.
Appeared in Compliance—The current permit was issued on 4 March 2015. The most recent permit
renewal and CY 2013 and EI were due 30 Jan 2015, both submitted on 30 Jan 2015. Next permit
renewal is Nov 2022 with emission inventory for CY 2021.
B. A.3. 2D .0503,"Particulates from Fuel Burning Indirect Heat Exchangers"—subject sources are
boilers(ES-014 &ES-013). Boilers limited to 0.41 lbs PM/mmBtu.
Appeared in Compliance - Boilers combust primarily natural gas, using fuel oil only for backup
during curtailment/testing/supply interruptions. AP-42 PM emission factor for natural gas is
0.007lb/mmBtu and for No. 2 fuel oil is 0.02 lb/mmBtu,both of which are well below the limit.
C. A.4. 2D .0515, `Particulates from Miscellaneous Industrial Processes" —all sources subject,
except for boilers, generator and dryer. PM from these sources shall not exceed the allowable
emissions rate determined by E=55x(P)'-" _40.
Appeared in Compliance - Highly efficient fabric filters and high efficiency cyclones control
particulate emissions. Sources are operated the same as during last permit renewal evaluation.
Nothing indicates non-compliance.
D. A.5. 2D .0516, "Sulfur Dioxide Emissions from Combustion Sources" — subject sources are the
boilers(ES-013 &ES-014), generator(ES-016), and grain dryer(ES-019). Sources are limited to 2.3
lbs S02/mmBtu.
Appeared in Compliance - Facility records indicate exclusive use of natural gas in the boilers, with
use of low sulfur #2 fuel oil only when curtailed by gas company; exclusive use of natural gas in
dryer; and exclusive use of low sulfur fuel oil in generator. Facility has not used fuel oil in the boilers
since 2005. AP-42 SO2 emissions factor for natural gas is 0.00061bs/mmBtu, and for No. 2 fuel oil is
0.51 lb/mmBtu,both well below the limit.
E. A.6. 2D .0521, "Control of Visible Emissions"—Visible emissions from emission sources limited
to 20%opacity.
Appeared in Compliance — At the time of inspection, there were intermittent fugitive emissions
ranging from 5-10% opacity were observed in the receiving pits where sorghum and soybean were
being offloaded, and no visible emissions were noted from any other of the operating sources.
Neither the grain dryer nor the generator were operating during the inspection. Mr. Batts stated there
have been no issues regarding visible emissions. If emissions are observed the system is shut down
and the problem is corrected.
F. A.7. 2D .0524, "New Source Performance Standards" — subject sources are the boilers. Sources
are limited to 0.5% sulfur by weight in the fuel combusted. Requires monthly fuel use records and
_ semi-annual reporting.
Appeared in Compliance — Natural gas is the primary fuel; fuel oil has not been combusted since
2005. Mr. Batts had a log of fuel burned,which indicated zero fuel oil used in 2016, and that no fuel
oil has been combusted so far in 2017. A fuel certification from the fuel supplier was available, and
stated that fuel supplied to the facility was less than 0.5% sulfur by weight. The semi-annual
reporting was received on 26 January 2017 and 12 July 2017 and indicated compliance.

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G. AS 2D .0535, "Notification Requirement" — subject sources are entire facility. Requires
notification of excess emissions that lasts more than 4 hours.
Appeared in Compliance— We reminded Mr. Batts of this requirement. Mr. Batts state there have
not been any occurrences of excess emissions which would require a notification. No complaints
have been received by either DAQ or by the facility.
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H. A.9. 2D .0540, "Fugitive Dust Control Requirement." — subject source is entire facility. The
Permittee shall prevent fugitive emissions from the facility from causing or contributing to
substantive complaints or excess VE beyond the property boundaries.
Appeared in Compliance — I noted light fugitive emissions at the receiving operations where
sorghum and soybean were being offloaded, but no dust emissions appeared to leave the property.
Mr.Batts stated that he has not received any dust complaints; no dust complaints associated with this
facility have been received by DAQ since the last inspection. The facility has a process in place to
record and address complaints if they are received.
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I. A.10. 2D .0611, "Fabric Filter Requirement"—subject devices are those operating on the hammer
mills, truck receiving, ground grain negative air system, pneumatic receiving, mixed feed turnheads,
and receiving turnheads. Requires at least an annual internal inspection, and periodic I&M per j
manufacturer specs.
Appeared in Violation—Annual internal inspection records for each device were available,but record -
keeping is still very unorganized. Mr. Batts tracked down work orders from an outside contractor
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hired to perform annual maintenance on the facility's baghouses. The dates for these inspections are
in the table below.The facility also monitors, daily,the magnahelic gauge reading on each bagfilter to
ensure proper operation of the device and when problems are found corrective action is taken.
NOTE: According to facility records, bagfilter CD-218 had missed the annual inspection.cycle at the
time of inspection. Additionally, the inspection records provided to the last inspector, during the 27
April 2017 inspection, do not match with the ones provided during this inspection, indicating a
problem in their recordkeeping,and unreliable records.
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CD-107 12/19/16
CD-123 12/14/16
CD-124 12/14/16
CD-129 12/19/16
CD-133 Removed in 2014
CD-212 12/26/16
CD-312 12/26/16
CD;4,22 10/25117 astral work order
J. A.11. 2D .0611,"Cyclone Requirement"—subject devices are those operating on the pellet coolers.
Requires at least an annual inspection.
Appeared in Compliance — Records of inspection were not readily available, but when finally
produced, did confirm an annual inspection for each cyclone. The availability and quality of cyclone
maintenance and inspection records have been an issue for several years.
K. A.12. 2D .1111,Prepared Feeds Manufacturing NESHAP (GACT 7D)- subject sources are areas
of plant at the point of.and after the introduction of Manganese and/or Chromium into the feed mix.
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Requirements include: recordkeeping of monthly housekeeping duties, monthly load-out chute
inspections, and quarterly cyclone inspections; storing chromium/manganese raw materials inclosed
containers; operating cyclones according to good air pollution practices; preparing an annual
compliance certification (ACC) by March I", submitting to the DAQ only if deviations have
occurred.
Appeared in Violation —Records provided for the monthly housekeeping activities, monthly loadout
chute inspections, and quarterly cyclone inspections appeared incomplete. Mr. Batts found records
for quarterly cyclone inspections for Q1 and Q4, but inspection records for Q2 and Q3 were missing.
Mr. Batts sent a follow-up email with work orders for all cyclones dated 5-1-17 and 7-5-17 that seem
to indicate inspections were done, but the records were incomplete. For each of the work orders
submitted, there was only a checklist available for one of the three permitted cyclone units. The
facility monitors fan amperage on a daily basis, which is a good indicator on how the cyclones are
operating, but it does not meet the records requirement for quarterly inspections. We reviewed at
least one daily/weekly housekeeping record for each month. The main issue with the current
housekeeping/cleaning form the facility uses is that it is sometimes difficult to determine when
housekeeping duties are completed in all areas of the facility. We informed Mr. Batts that he needed
to be able to show that housekeeping duties are being conducted in all areas of the facility with a clear
sign off section indicating the work is completed. The facility also continues to record fan amperages
on a daily basis, which is an indicator on how the cyclone is operating; additionally, the facility has
an automated alarm system on each cyclone that notifies the operator if the bindicator on the auger
under each cyclone has stopped moving, indicating a plugged cyclone. The system automatically
shuts the pellet coolers down until the auger is unclogged. Micronutrients containing Chromium and
Manganese are received in bags/sacks varying in weight but all are hand opened and poured into the
small, lidded bins above the mixer; the bin lids are only open when materials are being added. The
CY2016 ACC was available on site, and a copy was submitted to DAQ, received on 21 February
2017,due to a deviation noted during the last inspection.
L. A.13. 2D .1111, Reciprocating Internal Combustion Engine NESHAP (GACT 4Z)— subject
source is the generator engine. Requires a non-resettable hour meter be installed; operating less than
k 1.00 hrs/yr for maintenance/readiness testing; and annual maintenance including:.changing oil and oil
E filter, and inspecting air cleaner and hoses/belts.
Appeared in Compliance—The engine is classified as an emergency engine since it only runs when
the facility is without power beyond their control. The engine was tested on 9/19/17 before Hurricane
Maria. Mr. Batts stated the generator was run for — 1 hour and consumed — 20 gallons of fuel. A
yearly inspection by Cummings Atlantic is scheduled for 17 November 2017. At the time of the
inspection,no one was working who knew how to obtain the reading on the non-resettable hour meter
i display. Mr. Batts provided a picture of the hour meter total indicating 79.4 hours of use. The facility
does participate with 4-County Electric in"load control"operations,where they voluntarily shutdown
main energy sources(i.e. pellet coolers and mixer),but Mr. Batts said the generator does not come on
in that situation. They still use electricity from the grid to run receiving and load-out operations.
M. A.14. 2D .1806, "Control and Prohibition of Odorous Emissions" —entire facility subject. The
facility shall prevent odorous emissions from causing or contributing to objectionable odors beyond
the property boundaries.
Appeared in Compliance — I detected no odors when entering and departing the facility. No
complaints have been received in the FRO DAQ or at the facility,according to Mr.Batts. The facility
has a process in place to record and address complaints if they are received.
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N. A.15. 2Q.0315,"Limitation to Avoid Title V"-entire facility subject. Limitation: PM10 emissions
shall not exceed 100 tpy. Restrictions: feed production is limited to 1,600,000 tons/yr; Grain dried is
limited to 200,000 tons/yr; Bagging operation is limited to 50,000 tons/consecutive 12-month period.
Requires monthly recordkeeping and annual totals.
Appeared in Violation — Monthly records appeared valid and complete, but they were not readily
available in a usable format. The facility exceeded their permit limit for the bagging operation.
During the inspection, Mr. Batts provided monthly totals that show the facility bagged 51,656 tons
from October 2016-September 2017. The bagging operation is limited to 50,000 tons/consecutive 12-
month period. During the previous inspection, in April 2017, the facility was close to this limit and
Mr.Batts stated that he may request a modification in the future to try to increase the limit on bagging
to allow for more of a margin of compliance. In a follow-up e-mail, Mr. Batts sent a production total
table that had a different total of 50,002 for the bagging operation this number is still above the permit
limit. In a previous inspection, Mr. Joshua Harris of FRO DAQ told Mr. Batts how close the facility
was to exceeding their bagged limit and suggested keeping a rolling total for each month. While it
does not appear that the facility exceeded the Title V actual emissions threshold, they did exceed the
permit limit after they were made aware of how close they were to exceeding.
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Feed production 679,148.00 tons 693,754.00 tons
Grain dried 24,037.83 18,278.01
Bagging operation 50,002 47,337.04
O. A.16. 2Q .0317, Avoidance of Boiler NESHAP (GACT 6.1)- would-be subject sources are the
boilers. Facility avoids applicability of this rule by burning NG, with fuel oil only as back-up during
emergencies/supply interruptions, testing and curtailment. Requires recordkeeping of fuel oil usage
and reason for usage. Notify DAQ within 30 days of switch to fuel oil outside of emergencies/supply
interruptions,testing and curtailment.
Appeared in Compliance — Facility burns natural gas exclusively, with fuel oil only burned as
backup. No fuel oil has been burned since 2005.
P. A.17. 2Q .0711, "Toxic Air Pollutant Emissions Limitation"- subject sources are the entire v
facility. Facility-wide emissions shall not exceed TPERs.
Appeared in Compliance—Compliance was determined during the most recent permit review, based
on,the sources operating as described. Sources are operated the same as during last permit evaluation.
Nothing indicates non-compliance.
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VII. NON-COMPLIANCE HISTORY SINCE 2010:
08 August 2011 —CAI—late reporting
15 Feb 2013 —NOD—late reporting
19 Dec 2013—NOD—recordkeeping deficiencies
14 Feb 2014—NOD—late reporting
18 August 2014—NOV late reporting
17 November 2014—CAI—NESHAP 4Z Guidance
13 June 2016—NOD—GACT 7D Deficiencies
VIII. 112R APPLICABILITY:
The facility does not store any of the listed 112(r) chemicals in amounts that exceed the threshold
quantities. Therefore,the facility is not required to maintain a written Risk Management Plan(RMP).

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IX. CONCLUSION/RECOMMENDATION
On 15 November 2017, Murphy-Brown, LLC — Bladenboro Feed Mill appeared to be operating IN
VIOLATION of the following rules/regulations: 2D .0611,Fabric Filter Requirement,2D .1111,Prepared
Feeds Manufacturing NESHAP(GACT 7D),and 2Q .0315,Limitation to Avoid Title V
I recommend issuing a Notice of Violation(NOV)for the violations cited above.
Pink Sheet Items:
-None
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