AQ_F_0900066_20141029_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: 10/31/2014
Facility Data Permit Data
Murphy-Brown,LLC-Bladenboro Feed Mill Permit 08155/R09
255 Bryant Swamp Road Issued 8/1/2014
Bladenboro,NC 28320 Expires 4/30/2015
Lat: 34d 33.1310m Long: 78d 49.7910m Classification Synthetic Minor
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
Keith Richard,Jr Kraig Westerbeek Katie Elmer MACT Part 63: Subpart 7D, Subpart ZZZZ
Mill Manager V.P. Feed Mfg and Environmental Engineer NSPS: Subpart Dc
[phone] Transportation [phone]
[phone]
Compliance Data
Comments: Inspection Date 10/29/2014
�(. Inspector's Name Heather Carter
Operating Status Operating
Inspector's Signature: _`( Q (1 .n_ Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: >o13ijy On-Site Inspection Result Deficiency
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2008 60.37 0.0400 4.73 0.2600 3.94 29.14 168.00
2004 75.31 0.2100 4.60 0.2400 3.70 34.24 156.00
* Highest HAP Emitted(inpounds)
Five 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) MACT/GACT APPLICABILITY:
Murphy-Brown, LLC — Bladenboro Feed Mill is subject to the Prepared Feed Manufacturer's NESHAP
(GACT 7D),and the Reciprocating Internal Combustion Engine NESHAP (GACT 4Z). They are avoiding
the Boiler NESHAP(GACT 6J)by burning NG only. All of these rules are captured in their current permit
and are discussed below under each specific stipulation.
2) 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.
3) SAFETY CONCERNS:
Hard hat, safety shoes, ear plugs and safety glasses are required.
4) SOURCE/FACILITY DESCRIPTION:
Murphy-Brown, LLC—Bladenboro Feed Mill is an animal feed 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 bias. 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.
5) EMISSION SOURCES:
Permitted:
t Emrssron F ,y Emission.Source Control Control System t `
otlp ' Description System ID Deschption ry
Elevator Operation
Truck grain receiving pit -107 Bagfilter
ES-001 CD-0% VE;pit 42 (corn) -5-10% VE; (850 square feet of filter area)
pit#1 (Limestone)-15-20% VE
ES-002 Receiving turnhead negative air system CD-1213 Bagfilter
CD-0% VE �—(332 square feet of filter area)
ES-003 Receiving turnhead negative air system CD-124 Bagfilter
— Not Operating (209 square feet of filter area)
ES-004 Pneumatic receiving system CD-129 Bagfilter
Not Operating �—(200 square feet of filter area)
ES-005 Pneumatic receiving system CD-li3 Bagfilter
FES-005
Not functional; CD removed 9114 (200 square feet of filter area)
ES-009 Ground grain negative air system CD-218 Bagf Iter
CD-0% VE (300 square feet of filter area)
ES-016a One(1)load-out system having twenty(20)
(NE 016a load-out bins N/A
0% VE
ES-016b rd-out system having twenty(20)
(NESHAP) Load-out bins N/A
0% VE
ES-017 Rail Car Receiving N/A
Not
Operating

U�ilB"14R°$'` t ol
ree ri t� DescripPoR System lt) AesOKept4oq t 1 4
�Truck grain receiving pit, 15,000 bushels/hr
ES-018 max throughput,with 3-sided shelter with N/A
roof
Newly installed, not operating yet
- Wet grain storage silo, 55,000 bushels
ES-020a capacity N/A
Newly installed,not operating yet
Wet grain storage silo, 55,000 bushels
ES-020b capacity N/A
Newly installed, not operating yet
jgtility Operation
Generator,No.2 fuel oil fired,750 KW,Onan'
ES-016 Model D970636382 and Serial 86930A,with
(NESHAP) turbocharger and low temperature aftercooler N/A
control devices.
Not Operating
ES-014 Natural millionBtu per hour
porch ore NC imam ea input) N/A
(NSPS)
as/No.2 fuel oil-fired boiler 20.925
VF
(S-01) Natural gas/No.2 fuel oil-fired boiler(20.925'.
NSPS million Btu per hour maximum heat input) N/A
Not Operating
Feed Mill Operation
ES-007a Hammer mill system(capacity: 53 tons/hour)
CD-0% VE CD-212 Bagfilter
1,620 s uare feet of filter area
ES-007b Hammer mill system(capacity: 53 tons/hour) ( q )
Not Operating
ES-008a Hammer mill system(capacity: 53 tons/hour)
CD-0% VE FCD-31-5Airlanco model 12IAST12-II bagfilter
1 640 square feet of filter area
ES-008b Hammer mill system(capacity: 53 tons/hour) ( , q )
CD-0% VE
Pelleting system
FES
-010 Three(3)cyclones installed in parallel
(capacity:60 tons/hour) CD-508
SHAP) CD-0% VE (54 inches in diameter each)
Pelleting system
ES-011 F'it
(3)cyclones installed in parallel
(capacity: 60 tons/hour) CD-608
(NESHAP) CD-0% VE (54 inches in diameter each)
_
Pelleting system Three(3)cyclones installed in parallel
ES-012 (capacity: 60 tons/hour) CD-708 (54 inches in diameter each)
�� CD-0% VE
Mixed feed tumhead negative air system
ter
ES-015 e feet
(capacity:36 tons/hour) CD-422
(NESHAP) (209 square feet of filter area)
CD- 0% VE
N/A
Natural gas-fired grain dryer,47.8 million Btu.
ES-019 per hr maximum heat input
Newly installed, not operating yet

'a M. MANI i t i,,s{ln c�
m
k s EissrQnSouKce, a Caatrol GontroM4st%rnr k
J Descrrptian ' ID �; { Desenpt oa System
ES-021 Grain dryer truck loadout N/A
Newly installed, not operating yet
ES-022 Bagging Operation N/A
Not Operating
Insignificant:
IES-108- Storage Silo
IES-107-Storage Silo
IES-106-Storage Silo
IES-104-Storage Silo
IES-103 -Storage Silo
IES-102-Storage Silo
IES-101 -Storage Silo
6) INSPECTION SUMMARY:
On 29 October 2014, Jeff Cole and I, Heather Carter, arrived at Murphy-Brown, LLC—Bladenboro Feed
Mill facility to conduct their annual compliance inspection. We met with Mr. Keith Richard, Plant
Manager. Since this is the first inspection for which Mr. Richard 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, as discussed in detail under the appropriate
permit stipulation below. There were no complaints recorded since the previous compliance inspection.
We reviewed the equipment list and found some errors that will be corrected in the upcoming permit
renewal. We toured the facility and found it to be relatively clean and observed 0%VE from all operating
sources except for the truck receiving pits. The VE from one pit (while the limestone truck was
unloading) spike occasionally to 40% but was a steady 15-20% for the duration of the unloading. The
second pit was receiving corn and the VE was much lower(5-10%) while it was unloading. Mr. Richard
stated that limestone is the only ingredient that dusts like that and that they used to unload it
pneumatically. He was not sure why they changed to receiving it in the pits. The dust did not appear to
be traveling offsite. The old (previously permitted) grain dryer was still located on site, but has been
disconnected from the fuel source and plans are to remove it from the site in the future.
7) 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 - submitted the permit renewal application and CY 2008 EI on time, next
inventory due Jan 2015 for CY 2013.
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 Ibs PM/mmBtu.
Appeared in Compliance — Boilers combust primarily NG, using fuel oil only for backup during
curtailment. PM emission factor for NG is 0.0075 lb/mmBtu, 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)011 -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.S. 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 42 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. SO2 emissions factor for NG is 0.0006 lbs/mmBtu, well below the limit.
E. A.6. 2D .0521, "Control of Visible Emissions" — subject sources are boilers, generator & grain
dryer. These sources are limited to 20% opacity.
Appeared in Compliance — At the time of inspection, 0% opacity was observed from the boiler
operating on NG. Boilers normally operate on NG and only use fuel oil as a backup. The new grain
dryer had just been installed and was not operating. The generator was also not operating at the time
of inspection. Mr. Richard 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. Richard stated that he would create and keep on hand a tracking method for fuel oil
combustion, in the event they burned fuel oil in the future. I explained to him that when they burned
fuel oil for any reason,he needed to be able to track the amount combusted monthly.
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. Richard stated that to the best of his knowledge this facility has had
no excess emissions that exceeded limits for more than four hours during the 16 months he's been on
site.
H. A.9. 2D .0540, "Fugitive Dust Control Requirement."—subject source is entire facility. Requires
facility to not cause or contribute to complaints or excess VE beyond property boundary.
Appeared in Compliance — We noticed no dust emissions leaving the property, when entering and
exiting the facility. No complaints have been received in the FRO DAQ or at the facility, according
to Mr. Richard, since the last compliance inspection. The facility has a process in place to record and
address complaints if they are received.
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 tunheads. Requires at least an annual internal inspection.

Appeared in Compliance — Annual inspection records for each device were reviewed and appeared
complete and valid. The last inspection date ranges from 2/7/14 to 2/27/14. The facility also records
magnahelic gauge readings daily as a way to ensure proper operation of the device. The second
pneumatic receiving line is not functional and the baghouse(CD-133)was removed in Sept 2014.
I 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 1/2/14 — 1/12/14). 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 V, submitting to the DAQ only if deviations have
occurred.
Appeared in Compliance - The compliance date for this rule was Jan 5, 2012. FRO DAQ received
the IN and NOCS by the due dates. ACCs for CY 2012 and CY 2013, b/c they had deviations during
those years, were received in the FRO by the due date. Records provided for the monthly
housekeeping activities, monthly load-out chute inspections and quarterly cyclone inspections
appeared complete and valid. 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. Richard did have copies of the IN and ACCs on site. He was missing the NOCS,
but stated that he would obtain a copy and keep it on site. I reminded Mr. Richard that the ACC is to
be prepared by 1 March 2015, and that only if there are deviations would they submit the ACC to
FRO DAQ.
L. A.13. 2D .1111, Reciprocating Internal Combustion Engine NESHAP (GACT 4Z)— subject
source is 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.
Deviation Noted—The compliance date for this rule was May 3,2013. The generator 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 rut 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 amoral inspection and
maintenance were dated 10 June 2013 and performed by outside contractor, Cummings Atlantic. I
reminded Mr. Richard that the annual oil change and inspection requirements are on a 12-month

basis. So,they should have changed the oil and inspected the generator's air cleaner/hoses/belts again
by 10 June 2014. I also reminded Mr. Richard that they can choose to utilize the oil analysis program
and showed him the requirements in his permit. The generator has a non-resettable hour meter.
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—We detected no odors offsite when entering or departing the facility. No
complaints have been received in the FRO DAQ or at the facility, according to Mr. Richard, 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. 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 records and annual totals.
Appeared in Compliance — Monthly records appeared valid and complete. Tons of feed produced
from Aug 2014 - Oct 2014= 188,000 tons. Zero grain was dried at this facility in 2014. 16,800 tons
of grain were bagged from Aug 2014 to Oct 2014. All processes are well below permit limits.
O. A.16. 2Q .0317, Avoidance of Boiler NESHAP (GACT 6,n- 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,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,testing and curtailment.
Appeared in Compliance—Facility burns NG exclusively, with fuel oil only burned as backup during
curtailment. No fuel oil has been burned since 2005.
P. A.17. 2Q .0711, "Emission Rates Requiring a Permit"- subject sources are the entire facility.
Facility emissions shall not exceed TPERs.
Appeared in Compliance— Sources are operated the same as during last permit evaluation. Nothing
indicates non-compliance. The new grain dryer has been installed but not yet operated.
8) 112R APPLICABILITY:
Based on visual observations and personnel interviews, this facility is subject only to the General
Provisions of the 112r regulation.
9) CONCLUSION/RECOMMENDATION
Pink Sheet:
• ES-001 is actually two pits controlled by one bagfilter; and receives soft ingredients (not just
grain)
• CD-1213 should be CD-123
• ES-018 has 2, %:walls and a roof
• ES-007a&b and ES-008a&b: each set is controlled by one of two like bagfilters (Airlanco model
# 100AST-10, 1640 sq.ft filter area)
• CD-315 should be CD-312
• ES-012 need to add(NESHAP) in Emission Source ID cell in equipment table
• IES-105 appears to have dropped off the Insignificant list at some point Facility has 8 silos co-
located; 5=76,000 bushel capacity and 3=94,000 bushel capacity

Based on the observations made during the 29 October 2014 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 deviation noted above.
Recommend issuing a Notice of Deficiency(NOD)for the deviation noted above.
/hsc
Follow-Up Information:
On 11/4/14 Katie Elmer(Murphy-Brown Environmental Engineer) spoke with me regarding the missed
annual oil change/I&M for emergency engine ES-016. Slie stated that an internal environmental program
audit had been performed at this facility earlier in 2014. The auditor gave a satisfactory rating for the oil
change/I&M requirement because he interpreted the term "annual'to mean any time during the calendar
year, and the facility still had time in the year to complete this requirement. She said it appeared to be a
case of misinterpretation b/c if the auditor had realized the requirement was to conduct this activity within
12 months from the previous date, he would have advised the facility that the needed to complete it before
X date. The facility was also of the understanding(possibly,from interaction with the auditor)that they
needed to complete this activity before the end of 2014.
I explained to Mrs. Elmer that the term "annual," in the RICE NESHAP specifically,means within 12
months of the last date of the activity. In May 2014,DAQ asked EPA to interpret the meaning of
"annual"in this rule,to ensure that we were implementing the requirement according to the intent of the
rule. It appears that Murphy-Brown was thinking through the issue and was diligently evaluating the
compliance status of this facility with respect to this rule. Unfortunately a misinterpretation led to a
deviation. Due to the obviousness of their efforts to comply, and vague wording in the rule, I recommend
issuing a Compliance Additional Information letter to the facility instead of the Notice of Deficiency, as
indicated by our guidelines.