AQ_F_0900066_20111208_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: 12/12/2011
Facility Data Compliance Data
.Murphy-Brown,LLC-Bladenboro Feed Mill Inspection Date 12/08/2011
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 Violation-procedures
SIC: 2048/Prepared Feeds Nec Action Code FCE
NAILS: 311119/Other Animal Food Manufacturing On-Site Inspection Result Compliance
Contact Data Permit Data
Facility Contact Authorized Contact Technical Contact permit 08155/R06
Greg Ewing Terry Coffey Katie Elmer Issued 5/28/2010
Facility Complex President Murphy-Brown Environmental Engineer Expires 4/30/2015
Manager East [phone] Classification Small
Permit Status Active
[phone] [phone]
Inspector's Signature: , ' Comments:
Date of Signature:
12 P_1 f1
MACT/GACT APPLICABILITY:
Murphy-Brown, LLC — Bladenboro Feed Mill is subject to the Prepared Feed Manufacturer's NESHAP
(GACT 71)) because they use products containing Chromium in concentrations>0.1% and Manganese in
concentrations >1% in their feed product. They have submitted the initial notification and will need to
submit the notice of compliance status by 4 May 2012. The compliance date is 5 January 2012. EPA
recently issued a "No Action Assurance" letter to the industry that basically waives the requirement for
facilities to provide documentation of the 95% or greater PM control efficiency for the cyclones. All
other requirements are still in effect.
They are also subject to the Reciprocating Internal Combustion Engine NESHAP (GACT 4Z) because
there is an emergency generator on site that has an existing diesel-fired compression ignition (CI)engine.
According to 63.6645(a)(5), Initial Notification is not required because this is an existing emergency
engine. The following requirements shall be met by the 3 May 2013 compliance date:
!. Install non-resettable hour meter(63.6625(f))
+ .. Minimize idle time during start-up(63.6625(h))
o Change oil and filter every 500 hours of operation or annually, whichever comes first(Table 2d);
Inspect air cleaner every 1,000 hours of operation or annually, whichever comes first(Table 2d);
and
•: Inspect all hoses and belts every 500 hours of operation or annually, whichever comes first, and
replace as necessary(Table 2d).
They are also subject to the Boiler NESHAP (GACT 6J) because they operate two (2) 20mmBtu NG/No.
2 fuel oil fired boilers on this site. They notified this office, by the due date, that they are subject to the
rule. However, since they are only using fuel oil as a backup during curtailment, they will not be required

to comply with any other requirements of this rule unless and until they combust fuel oil outside of testing
or curtailment scenarios.
DIRECTIONS:
Murphy-Brown, LLC —Bladenboro Feed Mill facility is located on Bryant Swamp Road in Bladenboro,
$laden 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 (there is a fabric filter installed on each mill) 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:
, Emissron Emission Source Control Control System
sSoureeID Description „System ID T3escripton;
Elevator Operation
ES-001 truck rain receiving it CD-107 'bagfilter 900 square feet of filter area
g gp g ( q )
ES-002 receiving turnhead negative air system CD-123 =bagfilter(300 square feet of filter area)
t ES-003 receiving turnhead negative air system CD-124 bagfilter(300 square feet of filter area) r
ES-004 pneumatic receiving system CD-129 ;bagfilter(200 square feet of filter area)
ES-005 pneumatic receiving system CD-133 `ba filter 200 square feet of filter area
p b y g ( q )
ES-009 ground grain negative air system CD-218 =bagfilter(300 square feet of filter area)
ES-016a One load-out system having twenty load-out NIA
bins
ES 01b One load-out system having twenty load-out N/A
bins
ES-017 Rail Car Receiving N/A
. ...........
:Utility Operation
ES-016 :Generator,No. 2 fuel oil fired,750 kW,Onan
Model D970636382 and Serial 86930A,with N/A
i turbocharger and low temperature aftercooler

s .. „ ..
lannrsxontnission Soarce Control = Control System
oe DescriptionSystem 1D 1 escription
control devices.
_..........
ES-014 natural gas/No.2 fuel oil-fired boiler(20.925 N/A
(NSPS) :million Btu per hour maximum heat input)
...-
ES-013 .natural gas/No.2 fuel oil-fired boiler(20.925 N/A
(NSPS) million Btu per hour maximum heat input)
Feed Mill Operation
.. ... ...........
._ . .
ES-006 ,One(1)natural gas-fired grain dryer(15 million ' N/A
Btu per hour maximum heat input)
one(1)hammer mill(capacity: 53 tons per 'bagfilter(1,620 square feet of filter
ES-007a hour) CD-212 area)
.._ ----------- ...
ES=007b one(1)hammer mill(capacity: 53 tons per CD
bagfilter(1,620 square feet of filter
hour) area)
one(1)hammer mill(capacity: 53 tons per Airlanco model 121 AST 12-II
ES-008a hour) CD-314 bagfilter(2,384 square feet of filter
area)
Airlanco model 121AST12-II
one(1)hammer mill(capacity: 53 tons per
ES-008b hour) CD-314 bagfilter(2,384 square feet of filter
area)
CD-508
ES-0 and F Three Pellefing system(capacity: 60 tons per 608 and CD Three cyclones installed in series
ES-012 hour for each unit) 708 (54 inches in diameter each)
�_ ......_ ............. ...........
ES-015 Mixed feed turnhead negative air system CD-422 bagfilter(300 square feet of filter
(capaeity:36 tons per hour) area)
INSIGNIFICANT SOURCES:
Source'
"IES-108-Storage Silo
IES-107-Storage Silo
IES-1�06-Storage Silo
DIES-104-Storage Silo
IES-103 -Storage Silo
IES-102-Storage Silo
.IES-10i -Storage Silo
INSPECTION SUMMARY:
On 8 December 2011, 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 reviewed the fuel
usage records, fuel oil supplier certification, bagfilter and cyclone records, and community complaint
records. 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 low sulfur fuel oil and the same tank
supplies all sources. Vendor certification was on site. Bagfilter/cyclone inspection and maintenance
records appeared complete and valid. There were no new complaints recorded since the previous
compliance inspection. The current permit does not include stipulations for the three(3)federal rules this
facility is subject to: GACT 4Z, GACT 7D, and GACT 6J. We discussed GACT 7D, the feedmill rule, in

detail because the compliance date is quickly approaching. I told Mr. Hinson that I would email him a
copy of the permit stipulation for this rule so that he could go line by line and snake sure he would be in
compliance with all the monitoring, inspection, maintenance, recordkeeping and reporting requirements
by the compliance date.
PERMIT STIPULATIONS:
A.2. 2D .I111, 40 CFR Part 63, Subpart 7D, "NESHAP for Prepared Feed Manufacturing" —
subject sources are those at and after the point where chromium and/or manganese are introduced
Appeared in Compliance—The facility submitted the initial notification by the due date. The compliance
date is 5 January 2012 and the Notification of Compliance Status is due by 4 May 2012.
A.3. Emission Inventory Requirement—subject sources are the entire facility.
Appeared in Compliance- submitted CY 2008 on time,next inventory due Jan/Feb 2015 for CY 2013.
A.4. 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.S. 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. High efficiency fabric filters and triple cyclone banks control particulate
emissions.
A.6. 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 #2 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.7. 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 boilers operating on
NG. Boilers operate on NG and only uses 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.
A.B. 2D .0524,"New Source Performance Standards"—subject sources are the boilers.
Appeared in Compliance—Generally, the semi-annual reports have been received on time, however most
recent report was late. Facility was issued a CAI. 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.9 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 regulations for more than four hours.
A.10. 21) .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.11. 21) .0611, "Fabric Filter Requirement" — subject devices are those operating on the hammer
mills, truck receiving, ground grain negative air sys, 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.12. 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 .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.
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 8 December 2011 inspection, Murphy-Brown, LLC —
Bladenboro Feed Mill appeared to be operating in compliance with the requirements outlined in their
current air permit.
/hsh