AQ_F_0900066_20121107_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: 11/13/2012
Facility Data Compliance Data
Murphy-Brown,LLC-Bladenboro Feed Mill Inspection Date 11/07/2012
225 Bryant Swamp Road Inspector's Name Heather Hawkins
Bladenboro,NC 28320 Operating Status Operating
Lat: 34d 33.1310m Long: 78d 49.7910m Compliance Code Compliance-inspection
SIC: 2048/Prepared Feeds Nec Action Code FCE
NAICS: 311119/Other Animal Food Manufacturing On-Site Inspection Result Compliance
Contact Data Permit Data
Facility Contact Authorized Contact Technical Contact Permit 08155/R07
Doug Hinson Al Searles Katie Elmer Issued 10/19/2012
Plant Superintendent V.P.Feed Manufacturing Environmental Engineer Expires 4/30/2015
[phone] and Transportati [phone] Classification Synthetic Minor
[phone] Permit Status Active
Inspector's Signature: Comments:
Date of Signature:
MACT/GACT APPLICABILITY:
Murphy-Brown, LLC —Bladenboro Feed Mill is subject to the Prepared Feed Manufacturer's NESHAP
(GACT 71)), the Reciprocating Internal Combustion Engine NESHAP (GACT 4Z) and the Boiler
NESHAP (GACT 6J). All of these rules are captured in their current permit and are discussed below
under each specific stipulation.
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.
SAFETY.CONCERNS:
Hard hat, safety shoes, ear plugs and safety glasses are required.
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 bins. Liquid fat is pumped directly into a bin from the truck.
Vitamins and minerals are transferred, via one (1) of two (2) pneumatic receiving systems each with a

bagfilter installed, from the truck to the interior structure of the mill. Only one pneumatic receiving
system currently operates, the other is disconnected and the baghouse is just a shell. 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, there are 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.
PERMITTED SOURCES:
i Siflli �$ I II x'OI1T yNow `fl 0 `QIiIYl
lir�ei ,\ t u "SA>e ss:.C I
ZIM,�,.."�14£1l O[let fits U�:
truck grain receiving pit
ES-001 Operating with intermittent opacity from a CD-107 bagfilter(900 square feet of filter area)
hole in the elevator leg on top of mill
receiving turnhead negative air system
ES-002 Operating with 0%opacity CD-1213 bagfilter(300 square feet of filter area)
receiving turnhead negative air system
ES-003 CD 124 bagfilter(300 square feet of filter area
Operating with 0%opacity
pneumatic receiving system
ES-004 0 CD-129 bagfilter(200 square feet of filter area)
Operating with 0%opacity
pneumatic receiving system
ES-005 CD 133 bagfilter(200 square feet of filter area)
Not operating
ground grain negative air system
ES-009 o CD 218 bagfilter(300 square feet of filter area)
Operating with 0%opacity
ES-016a I One(1)load-out system having twenty(20)
a load-out bins N/A N/A
(NESHAP) Operating with 0%opacity
ES-016b One(1)load-out system having twenty(20)
a load-out bins N/A N/A
(NESHAP) Operating with 0%opacity ­"...-]--I e'__
Rail Car Receiving
ES-017 N/A N/A
Not operating
Generator,No.2 fuel oil fired,750 kW,
ES-016 Onan Model D970636382 and Serial
b 86930A,with turbocharger and low N/A N/A
(NESHAP) temperature aftercooler control devices.
Not operating
ES-014 natural gas/No.2 fuel oil-fired boiler(20.925
(NSPS)d million Btu per hour maximum heat input) N/A N/A
(NESHAP)c Operating on NG with 0%opacity
ES-013
d natural gas/No.2 fuel oil-fired boiler(20.925
(NSPS) million Btu per hour maximum heat input) N/A N/A
(NESHAP)
Not operating

i n ss�on Source �, raI cn roI system
y {L©tl
�.
One(1)natural gas-fired grain dryer
ES-006 (15 MBtu/hour maximum heat input) N/A N/A
Not operating
one(1)hammer mill(capacity. 53 tons/hour)
ES-007a o CD-212 bagfilter(1,620 square feet of filter area).
Operating with 0/o opacity m�
one(1)hammer mill(capacity: 53 tons/hour)
ES-007b CD-212 bagfilter(1,620 square feet of filter area)
�- Operating with 0%opacity n � m
ES-008a one(1)hammer mill(capacity: 53 tons/hour)
Operating with 0%opacity CD-315 Airlanco model 121AST12-II bagfilter
one(1)hammer mill(capacity: 53 tons/hour) (1,640 square feet of filter area)
ES-008b Not operating ..:<._.., .. .a
ES-010 Pelleting system(capacity: 60 tons/hour) CD-5 Three(3)cyclones installed in series
08
(NESHAP)a Not operating (54 inches in diameter each)
ES-011 Pelleting system(capacity: 60 tons/hour) CD-608 Three(3)cyclones installed in series
(NESHAP)a Not operating (54 inches in diameter each)
ES-012 �«Pelleting system(capacity: 60 tons/hour) CD-7 Three(3)cyclones installed in series
a ,
(NESHAP) Not operating (54 inches in diameter each)
ES-015 Mixed feed turnhead negative air system
a (capacity:36 tons/hour) CD-422 bagfilter(300 square feet of filter area)
(NESHAP) Not operating
INSIGNIFICANT SOURCES:
i
�Source�
IES-108-Storage Silo
IES-107-Storage Silo
IES-106-Storage Silo
IES-104-Storage Silo j
IES-103 -Storage Silo
IES-102-Storage Silo
IES-101 -Storage Silo
INSPECTION SUMMARY:
On 7 November 2012, I arrived at Murphy-Brown, LLC—Bladenboro Feed Mill facility to perform their
annual compliance inspection. I met with Mr. Doug Hinson, Plant Superintendent. We discussed the
requirement for fuel usage records and fuel oil supplier certification, and I reviewed housekeeping and
load-out(as required by GACT 7D)records. The facility has recently had turnover of staff that dealt with
retrieving info from their maintenance records system (METHOS) and was not able to pull up bagfilter
and cyclone inspection/maintenance records during the inspection. Mr.Hinson later emailed me copies of
bagfilter and cyclone records obtained from the system. The facility still uses NG for the boilers and only
uses low sulfur fuel oil (per vendor certification) as a back-up. The train engine and the generator use

ultra-low sulfur fuel oil and the same tank supplies all sources. There were no new complaints recorded
since the previous compliance inspection.
The following issues need to be addressed in the equipment list in their current permit:
• ES-001 is actually two pits controlled by one bagfilter;
• currently onsite is a 1533 sqft bagfilter operating on two hammer mills and a 803 sq ft bagfilter
operating on the other two hammer mills, Mr. Hinson stated that they have purchased two new
bagfilters (model # 100AST-10) having 1640 sqft of filter area to replace both the old units.
However, the air permit indicates there will be a 1640 sq ft bag filter and a 1620 sq ft bag filter
installed.
While on top of the mill, observing the emission points from several control devices, I noted that the
receiving pit elevator leg above the top of the mill had a hole in it that was allowing small amts of
particulate to become airborne. Mr. Hinson noticed it also and instructed an employee to temporarily
plug the hole until a metal patch could be added during the week of Nov 12", when maintenance
shutdown was scheduled.
PERMIT STIPULATIONS:
A.2. Permit Renewal and Emission Inventory Requirement—subject sources are the entire facility.
Appeared in Compliance - submitted the permit renewal application and CY 2008 EI on time, next
inventory due Jan 2015 for CY 2013.
A.3. 2D .0503, "Particulates from Fuel Burning Indirect Heat Exchangers" — subject sources are
boilers(ES-014 &ES-013)
Appeared in Compliance —Nothing to indicate non-compliance. Sources are operated same as during
last permit renewal evaluation. Boilers combust NG,using fuel oil only for backup during curtailment.
A.4. 2D .0515, `Particulates from Miscellaneous Industrial Processes" — subject sources are all
sources,except for boilers and generator.
Appeared in Compliance-Nothing to indicate non-compliance. Sources are operated same as during last
permit renewal evaluation. Highly efficient fabric filters and triple high-efficiency cyclone banks control
particulate emissions. Intermittent opacity was observed from the receiving pit elevator leg on top of the
mill. Mr. Hinson noticed same and instructed an employee to plug the hole until the scheduled
maintenance shutdown the following week when they could repair the hole with a metal patch.
A.S. 2D .0516, "Sulfur Dioxide Emissions from Combustion Sources" — subject sources are the
boilers(ES-014 &ES-013), generator(ES-016),and grain dryer(ES-006).
Appeared in Compliance - facility records indicate exclusive use of Natural Gas in the boilers, with use
of low sulfur 42 fuel oil (per vendor's certified statement)only when curtailed by gas company. Facility
hasn't used fuel oil in the boilers since 2005. The grain dryer uses NG only, and the generator operates
on low-sulfur diesel (per vendor's certified statement) and only runs once a month for testing and
maintenance.
A.6. 2D .0521,"Control of Visible Emissions"—subject sources are boilers, generator&grain dryer.
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 grain dryer was not
operating. It only runs approx 1 month out of a year(September time frame). The generator was also not
operating at the time of inspection. Mr. Hinson says that they never see smoke from the boilers.

A.7. 2D .0524,"New Source Performance Standards"—subject sources are the boilers.
Appeared in Compliance— Generally, the semi-annual reports have been received on time. The reports
indicate compliance with the standard in that the last shipment of fuel oil received contained <0.5%
sulfur. The facility also had on site at least 2 years of weekly fuel combustion records (the requirement is
for monthly records). Natural gas is the main fuel used. Fuel oil supplier certification is also on site.
A.8 2D .0535,"Notification Requirement"—subject sources are entire facility.
Appeared in Compliance - Mr. Hinson stated that to the best of his knowledge this facility has had no
excess emissions that exceeded limits for more than four hours.
A.9. 2D .0540,"Fugitive Dust Control Requirement."—subject source is entire facility
Appeared in Compliance—When entering and exiting the facility I noticed no dust emissions leaving the
property. No complaints have been received in the FRO DAQ or at the facility, according to Mr. Hinson,
since the last compliance inspection. The facility has a process in place to record and address complaints
as they are received.
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.
Appeared in Compliance - Records document routine inspections and maintenance on these devices. At
least one annual inspection has been conducted on each device in the last 12 months.
A.11. 2D .0611,"Cyclone Requirement"—subject devices are those operating on the pellet coolers.
Appeared in Compliance - Records document routine inspections and maintenance on these devices. At
least one annual inspection has been conducted on each device in the last 12 months.
A.12. 2D .1111,Reciprocating Internal Combustion Engine NESHAP (GACT 4Z)—subject source is
generator
Appeared in Compliance — The compliance date for this rule has not yet passed. The generator is
classified as an emergency engine b/c it only runs when the facility is without power beyond their control.
When the facility participates with 4-County Electric in "load control" operations, 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 amts of electricity from the grid to run receiving and load-out operations.
As a courtesy, I emailed Mr. Hinson the compliance requirements for this engine.
A.13. 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.
Appeared in Compliance-The compliance date for this rule was Jan 5,2012. FRO DAQ received the IN
and NOCS by the due dates. They appear to be in compliance with the housekeeping activities and
bagfilter/cyclone inspections; however the facility is not keeping records of monthly load-out sock
inspections as required by the rule. It appears, based on visual observations, that they are monitoring the
performance of the load-out socks,just not recording this activity. The truck load-out socks are cloth and
are approx 1/2 ft-lft from the top of the truck, from rear to front because of the gradient in the load-out.
The required quarterly cyclone inspections are exceeded by the combination of weekly and monthly
inspections conducted by facility personnel. Facility personnel continue to record fan amperage on a
daily basis even though the rule was changed and this requirement is only for new facilities. The detailed
permit stip was added to this most recent permit. I explained the annual compliance certification (ACC)
requirement, due 1 March 2013; specifically that the missing records constitutes a deviation and must be
noted in the ACC and since there are deviations the ACC must be submitted to FRO DAQ.

A.14. 2D.1111,Boiler NESHAP(GACT 6.n- subject sources are boilers
Appeared in Compliance—The compliance date for the tune-up requirement in this rule has passed, but
due to expected rule amendments EPA issued a No Action Assurance (NAA) letter valid through Dec
2012. The anticipated changes would extend the tune-up compliance date to March 21,2013. I reviewed
the rule and the applicable requirements with Mr. Hinson. He is aware that a tune-up is required on both
the boilers and that they must submit the required NOCS no later than 120 days later. They must also
conduct a one-time energy assessment on the processes using steam produced by the boilers by March 21,
2014 and submit the required NOCS no later than 120 days later. These activities may be performed
while operating on NG.
A.15. 2D .1806,"Control and Prohibition of Odorous Emissions"—subject source is entire facility
Appeared in Compliance — I 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. Hinson. The facility
has a process in place to record and address complaints as they are received.
A.15. 2Q .0315,"Limitation to Avoid Title V"
Appeared in Compliance — Records show weekly/monthly/annual inspections and maintenance for the
bagfilters and cyclones. The records appear valid and complete. The facility has dried 40,000 tons of
grain so far in CY 2012,well below the limit.
FIVE YEAR COMPLIANCE HISTORY:
8 August 2011 —CAI for late reporting
112R APPLICABILITY:
Based on visual observations and personnel interviews, this facility is subject only to the General
Provisions of the 112r regulation.
CONCLUSION/RECOMMENDATION
Based on the observations made during the 7 November 2012 inspection, Murphy-Brown, LLC —
Bladenboro Feed Mill appeared to be operating in compliance with the requirements outlined in their
current air permit.
/hsh