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HomeMy WebLinkAboutAQ_F_0900066_20160518_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 j Date: 06/09/2016 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 Nee Permit Status Active NAILS: 311119/Other Animal Food Manufacturing Current Permit Application(s)None Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact SIP Brian Franklin John Sargent Katie Elmer MACT Part 63: Subpart 7D,Subpart ZZZZ Feedmill Manager General Manager-South Environmental Engineer NSPS: Subpart Dc (910) 863-2263 Central Region (910)293-5245 (910)296-3768 Compliance Data Comments: j Inspection Date 05/18/2016 Inspector's Name Heather Carter Inspector's Signature: // /1 �1 f�c Operating Status Operating i Compliance Code Compliance-inspection Action Code FCE Date of Signature: G/r�w On-Site Inspection Result Deficiency Total Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PM10 *HAP 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 i *Highest HAP Emitted(inpounds) FSve Year Violation History: Date Letter Type Rule Violated Violation Resolution Date 08/18/2014 NOV 2D.0524 New Source Performance Standards 08/28/2014 Performed Stack Tests since last FCE: None 1) 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 Business toward Bladenboro. Travel approx 1.5 miles to Bryant Swamp Road and turn right. The facility is .2 miles on the left. 1 2) SAFETY CONCERNS: Hard hat, safety shoes, ear plugs and safety glasses are required. Watch for truck traffic. 3) 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 j operating on NG,that provide steam for the manufacturing operations. 4) EMISSION SOURCES: Permitted: S# } v J. e- Elevattir[lperation - �� s ruck ain Tter Operaatting 0%opacity it (850 square feetlof filter area) ES-001 and soft ingredients it [CD-107 — Receiving turnhead negative air system � Bagfilter ES-002 Operating 0%o opacity CD-123 p g p y (332 square feet of filter area) ES-003 Receiving turnhead negative air system CD 124 Bagfilter Operating 0%opacity (209 square feet of filter area) ES-004 Pneumatic receiving system CD-129 Bagfilter Not Operating (200 square feet of filter area) Pneumatic receiving system Bagfilter ES-005 Not Functional [CD-133 (200 square feet toof filter area) Removed from site E Ground grain negative air system e feet o f ES-009 CD-[CD Operating 0%opacity (300 square feet of filter area) ES-016a One(1)load out system having twenty(20) (NESHAP) load-out bins N/A Operating 0%opacity ES-016b One(1)load-outsys having twenty(20) (NESIAP) load-out b N/A Operating 01 � — ES-017 Rail Car Receiving N/A Not Operating , Ui4 j 10 Truck grain receiving pit, 15,000 bushels/hr in FEs- 018 throughput,with partially enclosed shelter N/A Not Operating FES 020a Wet grain N/A storage silo,55,000 bushels capacity — Full of grain,not being dispensed ES 020b �i et gram storage silo,55 000 bushels capacity N/A Full of grain,not being dispensed Generator,No. 2 fuel oil fired,750 KW,Onan ES-016 Model D970636382 and Serial 86930A,with (NESHAP) turbocharger and low temperature afrercooler N/A control devices. Not Operating ES 014 Natural gas/No. 2 fuel oil fired boiler(20.925 (NSPS) million Btu per hour maximum heat input) N/A Operating high-fire on NO 0%opacity ES 013 Natural as/No. 2 fuel oil fired boiler 20.925 (NSPS) ,million Btu per hour maximum heat input) N/A i Operating low-fire on NG 0%opacity )flee pera .� tton 7 ——�. �, _ Hammer mills stem(capacity: 53 tons/hour) A�irlanco Model 100AST10 II Ba filter ES-007a y . CD 212 Bag filter 0%opacity (1,640 sq. ft.of filter area) Hammer mill system(capacity: 53 tons/hour) Aulanco Model 100AST10-II Bagfilter ES 007b CD 212 i ((( Operating 0%opacity f (1,640 sq.fr.of filter area) -------- Hammer mill system(capacity: 53 tons/hour) Airlan ES 008a co Model 100AST10 II Bagfilter D-312 C Operating 0%opacity (1,640 sq.ft.of filter area) Hammer mill system(capacity: 53 tons/hour) lance,Model 100AST10-II Bagfilter ES 008b CD-312 Operating 0°Io opacity � (1,640 sq.fr.of filter area) ES-010 Pelleting system(capacity: 60 tons/hour) Three(3)cyclones installed in parallel (NESHAP) Operating 0%opacity CD 508 n__— p y (54 inches in diameter each) ES--oil Pelleting system(capacity: 60 tons/hour) Three(3)cyclones installed in parallel (NESHAP) OperatingCD 608 0%o opacity (54 inches in diameter each) ES 012 Pelleting system(capacity: 60 tons/hour) � Three(3)cyclones installed in parallel (NESHAP) Operating 0%opacity CD-708 (54 inches in diameter each) Mixed feed turnhead negative air system O15 Bagfilter (capacrty:36 tons/hour) [CD-422 [(iHAP) Operating 0%opacity (209 square feet of filter area) Natural gas-fired grain dryer,47.8 million Btu ES 019 per hr maximum heat input i N/A Not Operating ES 021 Grain dryer truck loadout N/A Not Operating ES 022 Bagging Operation N/A Not Operating Insignificant: IES-101 Storage Silos 2Q.0102(c)(2)(E)(i) No Yes NoIES-102-Storage Yes IES-103-Storage Silos 2Q.0102(c)(2)(E)(i) F No F Yes IES-104 Storage Silos 2Q.0102(c)(2)(E)(i) No Yes IES-105a-Storage Silos 2Q.0102(c)(2)(E)(i) No I 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 IES 108 Storage Silos 2Q.0102(c)(2)(E)(i) No l —Yes 5) INSPECTION SUMMARY: On 18 May 2016, I, Heather Carter, arrived at Murphy-Brown, LLC — Bladenboro Feed Mill facility to conduct their annual compliance inspection. I met with the new facility contact, Mr. Brian Franklin, Mill Manager. Since this is the first inspection for which Mr. Franklin has been the point of contact, we reviewed the entire permit. We reviewed the records required for GACT 7D (Feed Mfg NESHAP), GACT 4Z(RICE NESHAP), bagfilters and cyclones, and facility throughputs. Recordkeeping was much improved from previous years, but there was still a deficiency with respect to the NESHAP 7D, as discussed in detail under the appropriate permit stipulation below. Mr. Franklin informed me of the following updates for the facility: they would be notifying this office of an upcoming name change for the facility, they had completed like-for-like replacements of their coolers, cyclones, and fans, and they had not received any complaints since the last inspection that he was aware of. He also stated that they had not been routinely exercising the emergency generator, but that they intended to start running it monthly for testing. We toured the facility and found it to be relatively clean and observed 0% VE from all operating sources. 6) 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 — CY 2013 renewal and EI due 30 Jan 2015, both submitted on 30 Jan 2015. Next inventory due Nov 2022 for CY 2021. k B. A.3. 2D.0503,"Particulates from Fuel Burning Indirect Heat Exchangers"—subject sources are f boilers (ES-014 &ES-013). Boilers limited to 0.41 lbs PM/mmBtu. Appeared in Compliance — Boilers combust primarily NG, using fuel oil only for backup during curtailment/testing/supply interruptions. AP-42 PM emission factor for NG is 0.007 lb/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)°11 -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. i 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 SO2/mmBtu. Appeared in Compliance - Facility records indicate exclusive use of NG in the boilers, with use of low sulfur #2 fuel oil only when curtailed by gas company; exclusive use of NG 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 S02 emissions factor for NG is 0.0006 lbs/mmBtu, and for No. 2 fuel oil is 0.51 lb/mmBtu,both well below the limit. i E. A.6. 2D .0521, "Control of Visible Emissions" — subject sources are boilers, generator & grain j dryer. These sources are limited to 20% opacity. j Appeared in Compliance — At the time of inspection, 0% opacity was observed from both boilers operating on NG. Boilers normally operate on NG and only use fuel oil as a backup. The new grain dryer was installed and ran in 2015, but was not operating during the inspection. The generator was also not operating at the time of inspection. Mr. Franklin stated that that they never see smoke from the boilers,but if they did they would shut it down and investigate and take corrective action. 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. Franklin had a log of fuel burned, which indicated zero fuel oil used in 2015 and thus far in 2016. He was not able to produce the receipt (which shows the sulfur content) from their last shipment of no. 2 fuel oil. He stated that since this fuel is only used in the engine used to move the railcars on site,they have not been storing these receipts. I reminded him that if they burn fuel oil for any reason, they would need to be able to show the sulfur content did not exceed 0.5% by weight. Semi-annual reporting has been on-time (most recent received 1/29/16) and appeared valid and complete. i G. A.8 2D .0535, "Notification Requirement" — subject sources are entire facility. Requires notification of excess emissions that lasts more than 4 hours. Appeared in Compliance - Mr. Franklin stated that to the best of his knowledge this facility has had no excess emissions since the last inspection. 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 noticed no dust emissions leaving the property when entering/exiting the facility. No complaints have been received in the FRO DAQ or at the facility, according to Mr. Franklin, since the last compliance inspection. The facility has a process in place to record and address complaints if they are received. 1 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 manufacturer specs. Appeared in Compliance — Annual internal inspection records for each device were reviewed and 1� appeared complete and valid. The last inspection date ranges from 1/8/16 to 1/16/16. The facility I I also monitors, daily, the magnahelic gauge reading on each bagfilter as a way to ensure proper operation of the device and when problems are found corrective action is taken. The second pneumatic receiving line is not functional and the baghouse(CD-133)was removed in Sept 2014. 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 - At least one annual inspection has been conducted on each device in the last 12 months (ranging between 2/11/16 —2/12/16). The facility inspects the cyclones for corrosion, erosion and any other structural damage every month, and also inspects for buildup internally on a quarterly and annually schedule. 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. Requirements include: recordkeeping of monthly housekeeping duties, monthly load-out chute inspections, and quarterly cyclone inspections; storing chromium/manganese raw materials in closed 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. Deficiency Noted - Records provided for the monthly housekeeping activities and quarterly cyclone inspections appeared complete and valid. The monthly load-out chute inspections were recorded through January 2016. Mr. Franklin stated that the forms were changed by their parent company and that the line item for this inspection was missing. He stated that the employee doing the inspections has not altered his routine and was still doing the inspections, the form just doesn't capture the info. He immediately made changes to the form to start tracking this info. The facility actually has two sets of eyes on the cyclones quarterly, operators and maintenance both perform inspections. Facility also continues to record fan amperages on a daily basis, which is a great 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. Mr. Franklin did have copies of previous ACCs on site; the most recent being the CY 2014 ACC dated 2/25/15. However, he was missing the CY 2015 ACC. He prepared the document and emailed it to me the next day. I reminded Mr. Franklin that the ACC is to be prepared by 1 March every year for the preceding year, and that only if there are deviations would they submit the ACC to FRO DAQ. Therefore, for the CY 2016 ACC, he would need to note a deviation(not preparing the 2015 ACC by the due date)and submit to this office. L. A.B. 2D .1111, Reciprocating Internal Combustion Engine NESHAP (GACT 4Z)— subject source is engine for the generator. Requires a non-resettable hour meter be installed; operating less than 100 hrs/yr for maintenance/readiness testing; and annual maintenance including: changing oil and oil filter, and inspecting air cleaner and hoses/belts. Appeared in Compliance—The engine is classified as an emergency engine b/c it only runs when the facility is without power beyond their control. 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 the generator does not come on in that situation. They still use small amounts of electricity from the grid to run receiving and load-out operations. The generator only comes on if the facility is completely without power, and then it only runs receiving and load-out operations. The most recent records provided for annual inspection and maintenance were dated 9 November 2015 and performed by outside contractor, Cummings Atlantic. The generator has a non-resettable hour meter. I did not verify the number of hours on the non-resettable hour meter during this inspection. M. A.M. 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 offsite when entering/departing the facility. No complaints have been received in the FRO DAQ or at the facility, according to Mr. Franklin, in the past year. The facility has a process in place to record and address complaints if they are received. 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/yr. Requires monthly _ recordkeeping and annual totals. Appeared in Compliance-Monthly records appeared valid and complete. Tons of feed produced in 2015= 711,285 tons. Grain dried in 2015= 36,607 tons. Grain bagged in 2015= 42,121 tons. All processes are well below permit limits. O. A.16. 2Q .0317, Avoidance of Boiler NESHAP (GACT 6J)- 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 NG exclusively, with fuel oil only burned as backup. No i fuel oil has been burned since 2005. P. A.17. 2Q .0711, "Toxic Air Pollutant Emissions Limitation"- subject sources are the entire 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. 7) NON-COMPLIANCE HISTORY SINCE 2010: 8 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 8) 112R APPLICABILITY: The facility does not use or store any chemicals that make it subject to or require a written Risk Management Program as required under 40 CFR Part 68. _1 it 9) CONCLUSION/RECOMMENDATION Based on the observations made during the 18 May 2016 inspection, Murphy-Brown, LLC —Bladenboro Feed Mill appeared to be operating in compliance with the requirements outlined in their current air permit,except for the deficiency noted for missing records with respect to NESHAP 7D. Recommend issuing a Notice of Deficiency(NOD)letter for said deficiency. Pink Sheet Items: - Change Equipment List description for ES-016 to reflect that it is an emergency engine. /hsc r i i i i