AQ_F_0400032_20100805_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY Smithfield Packing Company Inc-Tar Heel
NC Facility ID 0900055
Inspection Report. County/FIPS:Bladen/017
Dates 08/05/2010
Facility Data Compliance Data
Smithfield Packing Company Inc-Tar Heel Inspection Date-08/05/2010
NC Highway 87 Inspector's.Name Debra McHargue
Tar Heel,NC `28392 Operating Status Operating
Lat:34d_44.7900m Long:78d 48.3660m Compliance Code Compliance inspection
SIC: 2011 /Meat Packing Plants Action Code PCE
NAILS: 311611 /Animal(except Poultry)Slaughtering ! On-Site Inspection Result Compliance
Contact Data Permit Data
Facility Contact Authorized Contact Technical Contact permit 07221/T13
Sylwia LaBudde Tarry Qmess Sylwia LaBudde issued 11/28/2006
Environmental Vice President/General Environmental Expires. 2/28/2011
Coordinator Manager Coordinator Classification Title V
910 862-7675 Permit Status Active
(910)682-�7675 � (91`0).862-7675 ,
Inspector's Signatur Comments:
/ f
Date of Signature:
L' Directions to Site:
From FRO,take NC-87 southeast toward Elizabethtown. The facility is very large and is located on the
right. It is approximately 25 miles from FRO. Go to the main office and get a visitor pass. You go
through the FDA checkpoint located in the rear of the building.The engineers office is located on the
backside of the plant. It is behind the water towers and is in a metal building.
2. Facility,Description:
Smithfield Packing Company Tar Heel Division is a'hog slaughter,meat preparation,and rendering
operation. The facility has been in operation since 1992. The meat processing plant produces-only
fresh meat products.`It is the largest packing plant in the world.Hogs are slaughtered,processed,and
all,remains`are sent to the rendering operation for further processing. The material for rendering comes
from the Meat Processing Plant as well as dead stock, including the hogs not fit to be slaughtered. The
rendering operation produces animal feed ingredients including feed fat,plasma,blood meal,and bone
meal. Smithfield meat preparation plant operates 16 hours/day, 5 days/week,and 52 weeks/year. The
processing plant is sanitized during the third shift. The rendering operation runs 24 hours/day, 6
days/week,and 52 weeks/year. The facility employs 5,500 people and processes 32,500 hogs per day.
3. Preinspection Conference:
On 5 August,1.Debra McHargue, of NCDAQ FRO;met with the compliance contact Paul Wright,
P_lant_Engineer-and-Sy1-wia-LaBudde�Envir-onmental-Cor-dinator—'W-e-discussed the-additionaar-ecor-d-s
--- ----and documents and various improvements made to the RMP. I requested a tour through the engine
room and the roof to inspect the anhydrous ammonia system.

4. Inspection:
Mr.Kevin Dove;Refrigeration Technician;walked the whole roof top to inspect the anhydrous
ammonia piping and condensers. There were sections of the sheathing and insulation foam that had
been repaired after my last inspection. Mr.Dove showed me the places that had been-repaired. He
pointed out replaced pressure relief valves and isolation valves. He demonstrated his knowledge by
showing how he would isolate a leak:
Mr.. Dove informed me that the maintenance had improved due,to him being told he must or he would
be.let go. He was instructed to fix all the problems found on and in the system and complete.
maintenance per the manufacturer's recommendation:
Mr.Wright provided updates;which he had in his office,while Ms.LaBudde was in route to come back
to the office.
General Comments observed during the inspection:
• The inspection is based on the Prevention Program 3 as defined by 112r 40 CFR Part 68.The
facility exceeds the 10,000-pound limit for anhydrous ammonia located on site.
• Process Hazard Assessment(Subpart B)COMPLIANCE INDICATED:
o The worst-case scenario and alternative release scenarios were provided. This has been
updated by Ms.LaBudde recently and will be submitted to the EPA and provided to
DAQ FRO.
• Process Safety Information(68.65)COMPLIANCE INDICATED:
o The maximum intended inventory of the,anhydrousammonia was written on the outside
of the engine room and in the plan. This amount,will be increased to be sure that amount
is not lower than the actual amount., Ms.LaBudde will give FRO a new amount: She
stated she believes.it will be 486,000 lbs.
o Relief system design was available. f
o , Material and energy balances were'-available.
o A copy of the MSDS for anhydrous ammonia is located in the'refrigeration room and the
clinic room. It was also in the safety office and is available to contractors.
o The flow/block diagrams of the process are.located in the refrigeration engine-room
office.
o The severe lack of tagging on the system was addressed. Mr.Wright ordered'all the tags
and pulled someone from another section to attach them.
• Process Hazard Analysis(68.67)COMPLIANCE INDICATED:
o PHA's were conducted-2004-all corrections are recorded -
o PHA's were conducted-March 2007
o Stellar Group is used to run the PSM.
o PHA's were completed on 7-8 April 2009.
• Operating Procedures(68.69)COMPLIANCE INDICATED:
o SOPs for operating procedures were available. They are reviewed for all maintenance
activities.
• Training(68.71)COMPLIANCE INDICATED:
-=-- o—Em-lo--ee-tr-ainin -is-conducted on a-routine basis.T-he facili-has-started--r-o --ess-of -----
P -Y-- g tY P -�'
implementing a new training program.
o Mr.Wright created a training room to include equipment to train the refrigeration team.
o All of the people who handle the refrigeration system(including Ms.LaBudde and Mr.
Wright)received their certification in industrial refrigeration(1&2)in May and
September of 2009 by RETA,Mr.John,Sherrill.

• Mechanical Integrity(68.73)COMPLIANCE INDICATED:
o The maintenance employees document all repairs made to the refrigeration system while
conducting routine maintenance and other activities.
o The log indicates they are following manufacturer's recommendations for operation and
maintenance of equipment/process.
o During the'previous inspection,the system has several relief valves that are completely,
rusted.Mr.Wright had these replaced. Also,the insulation and sheathing are replaced as
needed because strong winds can tear it away.
• Management of Change(68.75)COMPLIANCE INDICATED:
o The facility implements a policy for management of change prior to start-up of the
process/operational change.
• Pre-Startup Review(68.77)COMPLIANCE INDICATED:
o The facili y` did, roper docum documentation demonstrating the safet3 o operating,
rovideP
maintenance,and emergency procedures for new and/or modified processes in place.
• Compliance,Audits(68.79)COMPLIANCE INDICATED:
o Records indicate the facility-conducted a compliance audit in March of 2004
and3/2/2007.
o The most recent compliance audit was performed on 4-5 March 2010.
• Incident Investigations,(6 8.8 1)COMPLIANCE INDICATED:
o The facility had recorded one accidene in 2005. A high-pressure liquid line gasket blew
out.The facility reported this loss.The EPA and OSHA responded to the incident.
o On 23 December 2008 the facility had a release of 54 lbs this incident was documented.
• Employee Participation(68.83)COMPLIANCE INDICATED:
o Employees are trained in the hazard,analysis,process safety management,emergency'
res onse.plan and SOPs on a routine basis.
p
o Employee interview of Kevin Dove,Refrigeration Technicican,demonstrated training
and knowledge of the'RMP and emergency action plan.
• Hot Work Permits(68.85)COMPLIANCE INDICATED:
o The hot work permits are located in the safety office.
o Hot work permits are signed and issued each time hot work is conducted.
+ Contractors(68.87),COMPLIANCE,INDICATED:
o -The facility provided the procedure for new contractors that work on the refrigeration
system that covered this section.
• Subpart E Emergency Response Program: COMPLIANCE INDICATED:
o The facility is coordinated the LEPC or other agencies.
o The facility had a mock incident training day on�5 June 2010-:
g y I t3' ,
COMPLIANCE HISTORY:
02/06/2004 Informational letter sent from FRO about odors
03/09/2004 Incomplete ACC-request additional information
j 06/14/2004 NOV-late reporting quarterly report `
05/10/2005 NOV-late reporting quarterly report
n Monitoring&Recordkee in
0/2008 CAI-requested Animal Fat Combustion and
09/3 q P g
10/13/2008 Emissions Inventory Additional Information—New Certification Form Required
-ll/_07�20D8 Compliance_AdslitionaLInformationiZequ-eec1 s� 4(I-CFRPart-68_(Risk_-M-anag ment)
03/27/2009 Notice of Violation-Deficiencies in Annual Compliance Certification
12/11/2009 Notice of Violation-2D.0539 Odor Control
03/11/2010 Notice of Violation-2D.0539 Odor Control

6).Comments and Compliance Statement:
Based on the information-provided during my inspection,this facility appeared to be in compliance of
j the RMP requirements.
/djm
Cc: DAQ Central Files(with DAQ#00336 112r.Checklist)
Mike Reid Toxics Protection Branch
❑ RCO Central Files(yellow) -
❑ FRO Facility Files(blue)
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North Carolina Division of Air Quality 9 92(r)Inspection Checklist-40 CFR Part 6S
DACE IV_ U U',t3 b
SUBPART A-GENERAL INFORMATION 3.OPERATING PROCE/nge
S-68.52 0.(„410cess equipment complies with generally accepted C.( rocess hazard analysis conducted with
Facility Name: ', a.O Written operating prres for each covere rocess good engineering practices,state and federal design rules recommendations aTd resolutions.
Mailing Addr ss: as required by 68.52 d.( ployees trained in new process(es)
b.( )SOPs updated wheneajor change occ s and prior 2. PROCESS HAZARD ANALYSIS 68.67
Physical A ress: S to startup of the chanrocess a.(• entify hazards associated with process 8.CO LIANCE AUDITS-68.79
C- b.(rocess meets all state and federal design rules or a.( Owner/operator certified that they have evaluated
County: ,� 4. TRAINING-68.54ind stry standards if applicable(See Reference Card) compliance once every three years by person
O proper employe g • g (`J
Premise No.(if applicable): b 9 d f� a. Documentation of rm toe raining,,including C. esu of analysis documented and problems r soly kn�vledgeable of process
Phone Number: initial and refresher trg a min' um of every three d.( view updated every 5 years % �,j-15 mentationof audit findings and response
Facility Contact: ctu` ( v-; Pe f- years on process and ency esponse if applicable c.{ wo most recent compliance audit reports retained
Optional E-mail address: b.( )Operators are trainedw p cedures.prior to startup 3.OPE TING PROCEDURES 68.69 (YOptional Website address: of a rocess after a mh �pP ge(Emp Interview) a. ritten operating procedures for each covererocess 9.INCID�N INVESTIGATIONS 6�81a equired by 68.69 a.(�cidents with or p tential for catastrophic releases
Is facility subject to OSI3A PSM7 or N 5.MAINTENANCE 68.5b.(�Ps updated whenever major change occurs and prior have been investiga ed within 48 hours following
a.(.)SOPS for ensuring mical integrity t tartup of the changed process in ident
What is/are the process program level(s)?�' 0 b.(, )Employees trainedfoess maintenance activities c:( SOPS for maintenance activities,including b.( in
dings documented,reviewed with employees,and
c.( )Contractors trained r process maintenance activities locko to out;confined"space entry,opening process retained for five yeas
Is facility using administrative controls? Y or d.( )Inspection and tes ng on process*equipment equipm nt and piping,and other activities
10.EM
Are administrative controls documented and followed OYEE PARTIPATION 68.83
(� 6.COMPLIANCE' DITS-68.58 4. T NINa 68.71 a. Owner/operator has written plan for employee
properly? Y or N a.( )Owner/oper or certified that they have evaluated a.(qDocumentation of proper.employee training,including
ng pa c>pation i'
complianc once every,three years by person aj i I and refresher training a minimum of every three b.( ployees aware of risk management program,hazard
Has the facility met requirements for mom�ent system knowled able of process �1� on process and emergency response if applicable analyses,and process safety mana ement
specified in 40 CFR§68;15? (Y./or N b.( )Docui ntation of audit findings and response b.(�Qperators are trained in new procedures prior to'startup I g
(See Reference Card) a(-)Two ost recent compliance audit reports retained of a process after a major change(Emp Interview) 1 t.HO WORK PERMITS-68 �
a. lot work permits issued fe� ea"t or in l�ffected`J SUBPART B HAZARD ASSESSMENT -7.INC ENT INVESTIGATIONS-68.60 5:ME ANICAL INTEGRITY-68.73_. P
process �- p�r-sue {�►0 rye
a orst casescenario(s) ( Accidents with or potential.for catastrophic releases a.( OPs forensuring mechanical integrity 1�0
vt
b� t native release cenario(s I'll✓�,o have:been investigated within 48 hours following b.( Kmployee training for process maintenance activities 2.CONT CTORS-68.87 a �n
C.( v year accident history(Facility may show no incident C.( nspection and testing on process equipment,pressure a..(ty)-C3ntractors informed of potential fire p hazard and/or
accidents;,on-site and off-site history should be OFindings documented;reviewed with employees;and and storage tanks,piping systems,relief valves - release hazard associated with affected process(es)
retained for five P ( )
documented)(Seems Reference Card) years n t systems;emergency shutdown systems; b.��Owinedoperator
tractors aware o emergency action plan
c trols,monitoring devices,alarms,and pumps C. developed procedures for control of
SUBPART C -PREVENTION PROGRAM F R SUBPART D -PREVENTION PROGRAM FOR d.( nspection and testing follow recognized and generally contractors in to and out of affected process(es)
PROGRAM 2 FACILITIES (check to ensure at the PROGRAM 3 FACILITIES(check to ensure that the ac pted good engineering practices
following are documented and updated) followin are documented and updated) e. re uenc of testing and inspections consistent with SUPBART E-.EMERGENCYRESPON c
.f g P ) g P � ( q Y g P
I. PROCESS SAFETY INFORMATIO -68.48 1. PROCESS SAFETY INFORMATION-68.65 manufacturer's recommend tions and good enginee'ng _;pR0_G M(See Reference Card)
'a.( )MSDS for all regulated substance a.(.�'1�1 DS for all regulated substances practices �)
I fiC 0 � a.( •acility coordinated with I EPC;fire department,or(d�5t
Maximum intended inventory o regulated substances b._( low/block diagram of process(es) � -7 er local agencies
c.(')Safe upper and lower temper res,pressures,flows.. c-( ocess chemistry 6.MANAGEMENT OF CHANGE-68.75 �- b.( Facility has Emergency c Response Plan i appropriate)
,�11�.. g Y P (f ppropnate) �
and compositions d.( imum intended inventory of regulated substances a.(a-procedures that document basis for change;impact on �IJ
d (a-Employees are aware of Emergency Response Plan
( )Equipment specifications e.( afe upper and lowertemperatures,pressures,flows, health_and safety,and modifications to SOPS before . i
(det rmine through a nployee interviews) .
e.( ')Codes and standards us d to design,build,and operate compositions, change implemented , 1 L
P q y g d.( s facility included i{�community emergency response,
the process f. Evaluation of consequence of deviation from limits b.(,,yEmplo ees aware of change and trained in new SOPS plan? (Program 2 and 3 facilities
Are generally accepted a good engineering practices g•(Material of construction for equipment in process C.( }Employees and contractor involved in potential changes I ) $fa.✓-f> .
followed? Y or N h.(-Wiping and instrumentation diagram(P&IDs) that may affect their job tasks(Emp Interview)
Does facility have a Risk Mana ement o with all the
g
Electrical'classification required elements? (-Y-)or N
2. PROCESS H ARD REVIEW-68.50 j• (�l'ef system design and design basis 7.P,2E-STARTUP REVIEW-68.77. (for new and modified (,fee Reference-Card)
a.(.)Identify zards associated with process k.( ntilation system design process(es))
b.( )Proces meets all state and federal design rules or 1: piign codes and standards employed a.(instruction and equipment in'accordance with design
g Inspector's Name: L1F�#'t '
indu ystandards if applicable(See Reference Card) m.( aterial and energy balances(for sources constructed spe if .
c.( )R ults of review documented and problems resolved ofr June,2-1,1999) b.( afety,operating,maintenance,and emergency Signature:
d.O eview updated every 5 years n.( fety systems:(interlocks,s ppression,and/or procedures are in place and adequate I -
detection)
W_Prnnram(`nnrrlinatnr (`._Paninnat P_Pw ifltJ Q {ncncr tnr
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