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HomeMy WebLinkAboutAQ_F_0400039_20160512_CMPL_InspRpt NORTH CAROLINA DIVISION OF Fayetteville Regional Office AIR QUALITY Venture Milling-Ansonville NC Facility ID 0400039 Inspection Report County/FIPS:Anson/007 Date: 05/18/2016 Facility Data Permit Data Venture Milling-Ansonville Permit 07495/R08 North State Road 1627 and US 52 Issued 10/2/2012 Ansonville,NC 28007 Expires 9/30/2017 Lat: 35d 11.1320m Long: 80d 7.2160m Classification Small SIC: 2048/Prepared Feeds Nec Permit Status Active NAICS: 311119/Other Animal Food Manufacturing Current Permit Application(s)None Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact SIP Joe Potts Wayne Black Joey Baggett MACT Part 63: Subpart 7D Plant Manager Director PAB PAB Environmental (704)826-8318 Environmental Manager (252)348-4326 (252)287-5196 Compliance Data Comments: Inspection Date 05/12/2016 Inspector's Name Mike Thomas Inspector's Signature: 0 Operating Status Operating Compliance Code Compliance-inspection Action Code FCE Date of Signature: On-Site Inspection Result Compliance Total Actual emissions in TONSIYEAR: TSP S02 NOX VOC CO PMIO *HAP 2011 1.81 --- --- --- --- 0.4400 --- 2006 6.59 --- --- --- --- 2.11 --- i 1 * Highest HAP Emitted(inpounds) Five Year Violation History:None Date Letter Tyne Rule Violated Violation Resolution Date Performed Stack Tests since last FCE:None Date Test Results Test Method(s) Source(s)Tested L__ 1) Location/Directions Venture Milling-Ansonville is located at 2755 Old US Hwy 52 North(SR 1627),north of Ansonville, NC. In Wadesboro,take HWY52 N for 11 miles to Cedar Hill crossroads and turn left onto Old HWY52. The facility is approximately 2 miles on the left. Office is on the right side of building. 2) Safety Considerations Standard DAQ safety equipment required. While driving into facility,watch for trucks entering and exiting; during inspection,be alert for trucks/railcars in receiving and load out areas. There is no need to travel to the top of the silos at this facility, as emission points are clearly visible from the ground. 3) Facility and Process Description Venture Milling-Ansonville,a subsidiary of Perdue Agribusiness, is an animal feed blending operation,producing feed for poultry growers.This facility is permitted under Air Permit No. 74951108,effective from 2 October 2012 until 30 September 2017. Josh Harris and Robert Hayden,both of FRO DAQ conducted the last compliance inspection on 27 May 2015. j The facility blends mineral supplements with various feed stocks including rendered animal proteins, feather meal, and other ingredients.In the past,the supplements reportedly contained Manganese in concentrations greater than or equal to 1.0%by weight.As a result,the facility is subject to NESHAP Subpart 7D"Area Source Standards for Prepared Feeds Manufacturing".The only listed sources subject to this regulation are the Mineral Additive Mixing and Handling System and the Truck Loadout Operation(I)Nos. H and J).The facility does not have a pelleting operation and therefore is not subject to the cyclone requirements of NESHAP Subpart 7D. There is still a hammermill on-site,however, it is non-operational, and all associated ductwork and control devices have been removed. 4) Permitted Sources v � ---- Railcar,choke-fed receiving rt within a two No.A sided,roofed enclosure N/A N/A Not operating Track receiving pit within a two sided, Fabric filter No.B roofed enclosure CD-4 (620 square feet of filter area) Not operating Three storage silos,two with a capacity of No I 11,300 cubic yards and one with a capacity CD-3 Fabric filter (620 square feet of filter area) of 9,600 cubic yards CD-5� Pneumatic truck receiver operatingFabric filter No. C Not operating (245 square feet of filter area) No.H Truck loadout operation within a three sided,roofed enclosure N/A N/A (NESHAP_ - ) Not operating No. J Mineral Additive Mixing and Handling j F(IIIESHAP System N/A N/A ) ,� Not operating Insignificant/Exempt Activities MEN N, MEW On I S — 2Q .0102(c)(2)(E)(i) No Yes Truck loadout sp out on silo 1 j I-S2 2Q .0102(c)(2)(E)(i) No Yes Truck loadout spout on silo 2 I-S3 2Q.0102(c)(2)(E)(i) No Yes Truck loadout spout on silo 3 5) Inspection Conference On 12 May 2016 I, Mike Thomas, of FRO DAQ,met with Joe Potts,the Plant Manager and Facility Contact and.Evonne Green, a supervisor who handles the facility's safety and environmental programs. We discussed the following: a) Verged the FACFINDER. No changes were needed. b) Discussed the current production and what factors influence production. According to Mr.Potts,the facility's production is directly related to the price of soybeans. If the price of soybeans drops significantly below the price of their product then their consumers buy soybeans instead. c) I reviewed the maintenance and inspection logbooks for the baghouses. The facility continues to do bi-weekly inspections of the baghouses and associated ductwork. Entries in the logbook listed what was done and the person responsible for completing the work. d) I also reviewed the logbook for cleaning and housekeeping. Ms. Green stated that they conduct housekeeping inspections and cleaning every week. If conditions merit they will clean some areas more than once a week. I also observed the logbook where inspections and maintenance of the loadout shoot is kept. e) I inquired if the facility is still using additives that contain Cr and Mn in the percentages that trigger the 7D requirement. Ms. Green stated that it was her belief that the facilities supplements have never contained Cr and MN. She then provided me with a list of all of the supplements that the facility uses. f) Production: Year Tons of feed/week 2015 —1,100 2014 —2,225 2013 —3,000 6) Inspection Summary Ms. Green led me on an inspection tour of the facility which was not operating at the time due to the facility waiting on deliveries to continue production for the day. I observed the rail and truck receiving areas and the associated bagfilter CD-4. Both areas looked well-maintained, as did the bagfilter. Ms. Green accompanied me to the truck loadout point,which appeared to be clean and well-maintained.The chute appeared to be in good condition,with only minor wear visible. i i Ms. Green then took me to the ingredient mixing area.I observed little dust accumulation, and the required housekeeping appeared to be conducted regularly. Ms. Green explained how housekeeping occurs, and showed me the low pressure air lines used. She also explained that dust is cleaned up more regularly than is required by NESHAP Subpart 7D since it presents safety concern when accumulations reach a 1/8'inch threshold,possibly resulting in a combustible dust explosion. 7) Permit Stipulations a) A.2 2Q .0304 PERMIT RENEWAL AND EMISSIONINVENTORYREQUIREMENT—Entire facility subject. Submit permit renewal application and EI at least 90 days prior to permit expiration. Appeared to be in compliance—The deadline for the facility to submit their EI and permit renewal was 1 September 2012. The facility submitted both their EI on 8 August 2012 and the permit renewal application on 13 August 2012. b) A.3 2D .0515 —PARTICULATES FROMMISCELLANEOVS INDUSTRL9L PROCESSES. — Particulate control emissions from emission sources shall not exceed allowable emission rates. Appeared to be in compliance — Compliance was determined during the most recent permit review based on operating the source as described in the permit conditions. No changes have been made to operations since that determination. c) A.4 2D .0521 — VISIBLE EMISSIONS CONTROL REQUIREMENT—Visible emissions from each emission source shall not be more than 20%opacity. Appeared to be in compliance—The facility was not operating during my inspection. I did not observe any areas where PM had built up that might indicate that there are any issues with V.E. d) A.5 213 .0535 NOTIFICATIONREQUIREMENT- The facility is required to notify DAQ if excess emissions occur for more than a 4-hour period caused by a breakdown or other abnormal condition. Appears to be in compliance—According to Mr. Potts, the facility has had no exceedances, j breakdowns, or abnormal conditions requiring notification. e) A.6 213.0540—FUGITIVE DUST CONTROL REQUIREMENT—The Permittee shall not allow fugitive dust emissions to cause or contribute to complaints or excessive emissions beyond the facility's boundary. Appears to be in compliance—I did not observe any fugitive dust when driving into the facility, nor during the inspection.Mr. Potts stated that he was unaware of any dust complaints. A.7 2D .0611 —FABRIC FILTER REQUIREMENTS-Requires periodic I&M including, at a minimum, an annual internal inspection and recordkeeping." f) Appears to be in compliance—This facility performs and records weekly inspections and an annual internal inspection on each bagfilter.All records are well-kept and in good order,and the bagfilters appeared to be in good working condition. Maintenance staff takes before and after pictures of the bagfilters during the annual inspection,as well as the pressure gauges, and attaches them to the maintenance documents within the logbook. The last annual inspections were completed on 16 March 2016. g) A.8 2D .I I I I - "AMMMUMAVAILABLE CONTROL TECHNOLOGY"—Area Source Standards for Prepared Feeds Manufacturing(GACT 7D) -Compliance date for this GACT was 1/5/2012. Requirements are for: minimizing dust including monthly housekeeping, storing materials containing Cr and Mn in closed containers,closing mixer when in operation,reducing feed drop distance in loadout, and keeping doors closed; recordkeeping;NOCS due by 4 May 2012; and Annual Compliance Certification prepared by March 1st each year for the previous year. Appears to be in compliance—Venture Milling submitted their initial notification and Notice of Compliance Status before the due dates. Housekeeping at the facility is more stringent than what is required by NESHAP Subpart 7D. Sweeping and vacuuming occurs daily with more intensive cleaning being conducted on a weekly basis. In addition, cleaning can occur more frequently than daily if the need arises. All additives are stored in closed containers until they are added to the covered mixer. The truck loadout point had a chute installed to reduce the distance to the receiving truck. The chute on the loadout appeared to be in good shape but starting to show some signs of wear.The facility keeps a log of the maintenance and inspections of the loadout chute. Records jshowed the last inspection of the sock took place on 15 April 2016. The Annual Compliance Certification was prepared on 20 January 2016, and indicated no deviations. As indicated in the Inspection Conference above Ms. Green and Mr. Potts stated that the facility has never used additives that contain Cr or Mn in the production of their products and feel like the corporate office just made a _ blanket statement regarding the facility being subject to 7D. Ms. Green gave me the following list of additives: ethoxyquin,termin-8 choline P vitamin premix, P trace mineral, Copper Chloride, Pigmet (dry),threonine,DL methionine,lysine,ravabio AP 10%,and salt. Upon returning to the office I conducted an internet search for each of these additives and was able to determine that all of them are either amino acids or preservatives used in the prepared food industry. None of which contain Cr or Mn. I briefly discussed the facility requesting to not be subject to 71). Ms. Green stated that they would contact their Corporate office and inform them that they are not required to comply with 7D. She was uncertain what Corporate's response will be. i h) A.9 21) .1806—CONTROL AND PROHIBITION OF ODOROUS EMISSIONS-There shall be no odorous emissions from facility that causes or contributes to objectionable odors beyond the facility's boundary. Appears to be in compliance—No objectionable odors were noted while approaching the facility, nor while on-site during the inspection. Mr.Potts stated that he was unaware of any complaints regarding odor. 8) 112R Status This facility neither uses,nor stores, chemical compounds that require a written risk management plan under the Clean Air Act, Section 112R. 9) Non-compliance history since 2010 The facility has had no negative compliance issues since 2010. i 10) Comments and Compliance Statement Venture Milling-Ansonville appeared to be in compliance on 12 May 2016. Pink Sheet: Facility indicates they are not using products that contain Cr or Mn and are therefore not currently subject to NESHAP 7D. However,the rule requires the facility to submit a notification to this office,containing specified information,to be exempted from the rule. I briefly discussed this with Ms. Green and Mr.Potts. /mst I I I i i I I