AQ_F_0900066_20220907_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY Smithfield Hog Production-Bladenboro Feed Mill
NC Facility ID 0900066
Inspection Report County/FIPS: Bladen/017
Date: 09/09/2022
Facility Data Permit Data
Smithfield Hog Production-Bladenboro Feed Mill Permit 08155/R12
255 Bryant Swamp Road Issued 6/7/2018
Bladenboro,NC 28320 Expires 2/28/2023
Lat: 34d 33.1310m Long: 78d 49.7910m Class/Status 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
Philip Thoman John Sargent Katie Elmer MACT Part 63: Subpart 713, Subpart ZZZZ
Feed Mill Manager General Manager- South Environmental Project
NSPS: Subpart Dc
[phone] Central Region Manager
[phone] [phone]
Compliance Data
Comments:
Inspection Date 09/07/2022
r
Inspector's Name Stephen Allen
Inspector's Signature: �'---�.._. Operating Status Operating
Compliance Status Compliance- inspection
Action Code FCE
Date of Signature: C ![d tZ �- �` - Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PMI0 * HAP
2013 62.17 0.0300 4.88 0.2700 4.10 29.73 175.00
2008 60.37 0.0400 4.73 0.2600 3.94 29.14 168.00
* Highest HAP Emitted inpounds)
Five Year Violation History:
Date Letter Type Rule Violated Violation Resolution Date
10/30/2019 NOV/NRE NCGS 143-215.108 Control of sources of air pollution; 12/10/2019
permits required.
10/30/2019 NOV/NRE 21) .1111 Maximum Achievable Control Technology 12/10/2019
12/12/2017 NOV 21) .0611 Monitoring Emissions from Other Sources 05/15/2018
12/12/2017 NOV 21) .1111 Maximum Achievable Control Technology 05/15/2018
12/12/2017 NOV 2Q .0315 Synthetic Minor Facilities 05/15/2018
Performed Stack Tests since last FCE: None
Date Test Results Test Method(s) Source(s)Tested

I. DIRECTIONS:
Smithfield Hog Production — 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—1.5 miles to Bryant Swamp Road and turn right. The facility is 0.2
miles on the left.
II. SAFETY CONCERNS:
Hard hat, safety shoes, ear plugs and safety glasses are required. Watch for truck traffic.
III. FACILITY/PROCESS DESCRIPTION:
Smithfield Hog Production—Bladenboro Feed Mill is an animal feed manufacturing mill. They receive
corn, soybean, grains,trace mineral 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 (<15.5 % moisture) and grains pass through one (1) of four (4) hammer mills
(where each pair of hammer mills is controlled by a single bagfilter)and are transferred,via a distribution
system controlled by a bagfilter,to their respective bins. Liquid fat is pumped directly into a bin from the
truck. Vitamins and minerals(other than trace mineral)are received in bags and materials are then weighed
(how much depends on the feed they are making)and blended to make feed mash. The mash is transferred,
via a feed distribution system controlled by a bagfilter, to 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 operating
in parallel on each one of the coolers. After the feed has cooled it is loaded onto trucks and shipped to the
farms.
Wet corn(>15.5%moisture)is received in a separate receiving pit with a partially enclosed shelter and then
stored in one of two (2) silos until it passes through the grain dryer(none of these sources are controlled).
The corn is then stored in silos or the flat bag storage onsite until needed.
The facility also has two(2)NG/No.2 fuel oil-fired boilers,normally operating on NG,that provide steam
for the manufacturing operations, and a 750kW emergency generator.
This facility is subject to the requirements of NESHAP 7D, Prepared Feeds Manufacturing (GACT 713);
NESHAP 4Z5 RICE(Reciprocating Internal Combustion Engines)(GACT 4Z);and NSPS Dc,New Source
Performance Standards for Small Boilers. The facility is Synthetic Minor for PM 10.

IV. EMISSION SOURCES:
Emission Emission Source Control Control System
Source ID Description System ID Description
Elevator Operation
._ _. .__ ........ ____
Truck grain receiving pit, and soft i Bagfilter
ES-001 ingredients pit CD-107 (850 square feet of filter area)
Not operating Operating w/No VE
Bagfilter
ES-002 Receiving turnhead negative air system CD-123 (332 square feet of filter area)
Not! Operating Not Operating
»_... ..
Bagfilter
ES-003 Receiving turnhead negative air system CD-124 (209 square feet of filter area)
Not Operating
Not Operating
Bagfilter
ES-004 Pneumatic receiving system CD-129 (200 square feet of filter area)
Operating
Not Operating
Pneumatic receiving system _ Bagfilter
ES-005 CD-133 (200 square feet of filter area)
Operating
Not On Site
Bagfilter
ES-009 Ground grain negative air system CD-218 (300 square feet of filter area)
Operating
Not Operating______.....�._._..�..�
ES-016a } One (1) load-out system having twenty
(NESHAP) (20) load-out bins N/A N/A
f
Operating with 0% opacity '
ES-016b One (1) load-out system having twenty
(NESHAP) (20) load-out bins N/A N/A
Operating with 0% opacity
Rail Car Receiving
ES-017 Not Operating N/A N/A
i
Truck grain receiving pit, 15,000
ES-018 bushels/hr max throughput,with partially N/A N/A
enclosed shelter
Operating
Wet grain storage silo, 55,000 bushels
x
ES-020a ( capacity N/A i N/A
No Filling
Wet grain storage silo, 55,000 bushels
ES-020b capacity N/A N/A
No Filling

............... - .. ...... ...... ._.
.Utility Operation
Emergency Generator,No. 2 fuel oil fired, I
ES-016 750 kW, Onan Model D970636382 and I
(NESHAP) Serial 86930A,with turbocharger and low N/A N/A
temperature aftercooler control devices.
Not Operating
Natural gas/No. 2 fuel oil-fired boiler
ES-014 (20.925 mmBtu/hr maximum heat input) N/A N/A
(NSPS) Replaced with 20.4 mmBtu NG/FO boiler
z
Operation with 0% opacity
___...
ES-013 Natural gas/No. 2 fuel oil-fired boiler - 1
(20.925 mmBtu/hr maximum heat input) N/A I N/A
(NSPS) Operation with 0% opacity
I
P j
Feed Mill Operation
Hammer mill system
ES-007a (capacity: 53 tons/hour) Airlanco Model 100AST10-II
filter
Operating Ba g
CD-212 (1,640 sq. ft. of filter area)
Hammer mill system Operating without Air Supply;
ES-007b I (capacity: 53 tons/hour) Operation with 0% opacity
Operating
„ Hammer mill system
ES-008a (capacity: 53 tons/hour) Airlanco Model 100AST10-II
Operating Bagfilter
CD-312
Hammer mill system (1,640 sq. ft. of filter area)
ES-008b (capacity: 53 tons/hour) Operation with 0% opacity
j Operating
Three(3)cyclones installed in
Pelleting system
ES-010 parallel
(capacity: 60 tons/hour) CD-508
(NESHAP) O eratin (54 inches in diameter each)
P g Operation with 0% opacity
Three(3)cyclones installed in
ES-Ol 1 Pelleting system parallel
(NESHAP) (capacity: 60 tons/hour) CD-608 (54 inches in diameter each)
Operating °
Operation with 0% opacity
Pelleting system Three(3)cyclones installed in
ES-012 parallel
(NESHAP) (capacity: 60 tons/hour) CD-708 (54 inches in diameter each)
Operating °
I Operation with 0% opacity
Mixed feed turnhead negative air system
Bagfilter _
ES-015 (capacity:36 tons/hour) CD-422 E (209 square feet of filter area)
(NESHAP) Operating without Air Supply;
Operating Operation with 0°
/o opacity

Natural gas-fired grain dryer
ES-019 47.8 mmBtu/hr maximum heat input N/A N/A
Not Operating
Grain dryer truck loadout
ES-021 Operating with 5% opacity N/A N/A
V. INSIGNIFICANT EMISSION SOURCES:
Source Exemption Regula
tion Source of Source of Title
TAPs? V Pollutants?
IES-101 � �� � ' 2Q .0102(h)(5) No Yes
I
Storage Silos g i
IES-102 2Q .0102 (h)(5) No Yes
Storage Silos t ;
IES-10_3 2Q .0102(h)(5) No Yes
r
Storage Silos ,
- IES-104 2Q .0102(h)(5) m No Yes
Storage Silos
______.___-----------
IES-lOSa 2Q .0102(h)(5) No Yes
j Storage Silos
IES 106 2Q .0102 (h)(5) No Yes
Storage Silos
IES-107 1
Storage Silos
2Q .0102(h)(5) No Yes
i
` IES-108 �
f 2Q .0102 (h)(5) No Yes
Storage Silos ,
IES-022 2Q .0102 (h)(5) No Yes
Bagging Operation
3
IES-023 2Q .0102 (h)(5) No Yes
'Flat Storage Bagging System
VI. INSPECTION SUMMARY:
On 07 September 2022, I, Stephen Allen and Taijah Hamil of FRO DAQ, conducted an air quality
compliance inspection of Smithfield Hog Production — Bladenboro Feed Mill. We met with Philip
Thoman, Feedmill Manager, Greg Ewing, Regional Operations Manager, and Rob Richardson,
Environmental Resource Specialist.
Mr. Ewing reviewed the FACFINDER and updated information that needed to be changed. The updates
have been entered into IBEAM. We reviewed records for Inspection & Maintenance (I&M) on the
bagfilters and cyclones, and records for NESHAP 7D requirements. The facility has all the records for the
facility in three large binders. All housekeeping records looked well maintained. Cyclone and bagfilter
records were also maintained well and up-to-date. Mr. Ewing mentioned that a few controls had been
replaced but they were like for like. See section A.I I for a listing of which controls were replaced since the
last inspection.

Mr.Thoman and Mr.Ewing stated that the facility was interested in using totes of trace minerals instead of
bags. We informed the facility that as long as the totes were closed then that would be fine. DAQ Regional
Supervisor also confirmed that as long as the totes were closed,they could be used.Mr.Ewing informed us
that earlier this year they received a fugitive dust complaint from a lady in the area. He explained that the
fugitive dust was coming from the film that comes off the corn (also known as "bees wings") when it is
being dried in the grain dryer.The facility now has a screen over their dryer to control the dust and they are
also buying the complainant car washes. They have not received any complaints since then.
We toured the facility, which was operating during the inspection. We began at the rail car receiving pit
where a load of corn was being received. We observed brief fugitive emissions <5% opacity that did not
leave the enclosed receiving area. We observed the boilers operating on natural gas with 0% opacity. We
went through the permit with Mr. Thoman and observed each of the bagfilters operating with 0% opacity.
The air supply and pulse were functioning on all the bagfilters. The facility operates 24/7 with —25
employees.
Production:
Year Feed Production (t ) Grain Dried (t )
2021 640,262 49,986
2020 726,714 45,749
2019 d 693,794 183,278
2018 665,974 19,301
2017 678,789 245037
2016 6935754 181-278
VII. PERMIT STIPULATIONS:
A.2. 2Q .0304 & 2D .0202 "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— The facility's current permit expires 28 Feb 2023, and the next
permit renewal is due Nov 2022 with AQEI for CY 2021. The facility technical contact Katie Elmer
stated in an email she did not need assistance with their 2021 AQEI.
A.3. 2D .0503,"Particulates from Fuel Burning Indirect Heat Exchangers"—subject sources are
boilers(ES-014& ES-013). Boilers limited to 0.41 lbs PM/mmBtu.
APPEARED IN COMPLIANCE— The boilers combust primarily natural gas, using fuel oil only for
backup during curtailment/testing/supply interruptions. The facility has not burned any fuel other than
NG in the past year. AP-42 PM emissionfactorfor natural gas is 0.007 lb/mmBtu and for No. 2 fuel oil
is 0.02 lb/mmBtu, both of which are well below the limit.
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)" -40.
APPEARED IN COMPLIANCE—Compliance was determined during the most recent permit review
based on operating the source as describe in the permit conditions. No process changes have been
made in operations since that determination and all control devices were operating properly and being
inspected and maintained on a regular basis.

A.5. 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 S02/mmBtu.
APPEARED IN COMPLIANCE-Facility records indicate exclusive use of natural gas in the boilers,
with use of ultra-low suer#2 fuel oil only when curtailed by gas company;exclusive use of natural gas
in dryer;and exclusive use of ultra-low sulfur fuel oil in the generator. The facility has not usedfuel oil
in the boilers since 2005. AP-42 S02 emissions factor for natural gas is 0.0006 lbs/mmBtu, and for No.
2 fuel oil is 0.002 lb/mmBtu, both well below the limit. The emergency generator has not operated
since 2017 as it is inoperable due to mechanical issues.
A.6. 21) .0521, "Control of Visible Emissions" — Visible emissions from the emission sources,
manufactured after July 1, 1971, shall not be more than 20 percent opacity when averaged over a
six-minute period.
APPEARED IN COMPLIANCE — We observed no visible emissions from non fugitive emission
sources during the inspection. Overall, the facility appeared to be clean and well maintained.
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 and is the only fuel burned since the
last inspection. Fuel oil has not been combusted since 2005. The most recent semi-annual report was
received on 05 July 2022, appeared valid and complete and indicated compliance.
A.8 2D .0535, "Notification Requirement" — Facility-wide applicability. Requires notification of
excess emissions that lasts more than 4 hours.
APPEARED IN COMPLIANCE—Mr.Ewing stated that there have been no excess emissions events
since the last inspection. We did not observe any issues during the inspection.
A.9. 2D .0540, "Fugitive Dust Control Requirement." — subject source is entire facility. The
Permittee shall prevent fugitive dust emissions from the facility from causing or contributing to
substantive complaints or excess VE beyond he property boundaries.
APPEARED IN COMPLIANCE — Mr.Ewing stated that he had received one complaint from -a
neighbor across the street.regarding the "bees wings" that can be an issue when the grain dryer is
used. Mr. King stated the complainant had "bees wings"on their vehicle on days when the wind blew
in the right direction. The facility installed a mosquito type netting around the top of the drier that
seems to have solved the problem. The complainant never contacted FRO and the facility appears to
have made the necessary corrections to fix the issue.
A.10. 2D .0611, "Cyclone Requirement"—subject devices are those operating on the pellet coolers.
Requires at least an annual inspection and periodic I&M per the manufacturer's recommendations.
APPEARED IN COMPLIANCE — The facility has a logbook system that contains all of the
maintenance and inspection records for all of the control devices. Entries for the cyclones appeared
valid and up to date. The facility conducts inspections of the cyclones on a monthly basis (main focus
on inside of cyclone) and quarterly basis (more outside structure focus). The most recent monthly
inspection occurred on 15 August 2022. In addition, the facility conducts daily visual inspections and
records the fan amperage on each cyclone set.

A.11. 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. Requires at least an annual internal inspection, and periodic I&M per
manufacturer specs.
APPEARED INCOMPLIANCE—The facility has a logbook system that contains all the maintenance
and inspection records for all of the control devices. Entries for the bagfilters appeared valid and up to
date. The facility says their PM schedule is to conduct internal inspections of each bagfilter on a
monthly basis. They do appear to consistently conduct a quarterly inspection on each bag filter, and
that inspection is commensurate with the required annual internal inspection. Mr. Ewing mention that
a few controls had been replaced but they were like for like. See the replaced controls in the table
below.
Control Device Last Annual Inspection
CD-107 08/20/22
CD-123* 09/04/22
CD-124* 09/03/22
CD-129* 09/03/22
CD-133 Removed in 2014
CD-218* 09/03/22
CD-212 09/03/22
CD-312 09/03/22
CD-422* 09/04/22
*Replaced controls
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: performing monthly housekeeping duties,monthly load-out chute inspections,
quarterly cyclone inspections; visually observing cyclones weekly for good operation, and keeping
records of each activity; storing chromium/manganese raw materials in closed containers; operating
cyclones according to good air pollution practices;preparing an annual compliance certification(ACC)
by March lst, submitting to the DAQ only if deviations have occurred.
APPEARED IN COMPLIANCE —Monthly Housekeeping Requirement. During the inspection it
was noted that the facility was receiving the manganese containing product in bags, but they want to
start receiving the product in totes instead. Overall, the facility appeared clean and well maintained.
Monthly Truck Load-out Sock Inspection Requirement: Records appeared valid and complete.
Socks appeared to be in good condition and functioning properly. The last sock inspection was
completed on 15 August 2022.
Quarterly Cyclone Inspection Requirement: Inspections are completed at least quarterly (some
monthly inspections are also completed). The most recent inspection occurred on 15 August 2022.
Cyclone Visual Observation Requirement:_The facility records fan amperages daily, which is an
indicator on how the cyclone is operating. Also,the facility has an alarm system on each cyclone that
notifies the operator if the bindicator at the bottom of each cyclone has stopped moving, indicating a
plugged cyclone. The auger also has a speed sensor,and if it stops then the pellet coolers automatically
shut down until the auger is unclogged.
ACC Requirement: Mr. Thoman had the 2021ACC form dated 25 February 2022 indicating the
facility was in compliance with all permit stipulations.

A.13. 2D .1111, Reciprocating Internal Combustion Engine NESHAP (GACT 4Z�- subject
source is the generator engine. 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.
APPEARED IN COMPLIANCE — Mr. Thoman stated that the engine is not operable due to
mechanical issues, and that he has had multiple contractors attempt to repair it to no avail. He stated
that it has not operated since some time in 2017. Until and unless the engine starts operation, the
requirements above do not apply.
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 off-site when entering and departing the
facility. Mr. Ewing stated that the facility has received no odor complaints, and no complaints have
been received in the FRO DAQ.
A.15. 2Q .0501, "Limitation to Avoid "Synthetic Minor Facilities"- Facility-wide applicability.
Limitation: PM 10 emissions shall not exceed 100 tpy. Restrictions: feed production is limited to
1,600,000 tons/yr; Grain dried is limited to 200,000 tons/yr; Requires monthly recordkeeping and
annual totals.
APPEARED IN COMPLIANCE — Monthly records appeared valid and complete and show
compliance, well below the limits,for 2021. Data for 2021 (ytd) also indicates they will be well below
the limits: 640,262 tons feed produced and 49,986 tons grain dried.
A.16. 2Q .03179 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/supply interruptions, 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/supply
interruptions,testing and curtailment.
APPEARED IN COMPLIANCE—Facility burns natural gas only since the last inspection. No fuel
oil has been burned since 2005.
A.17. 2Q .07119 "Toxic Air Pollutant Emissions Limitation"- Facility-wide applicability.
Facility-wide emissions shall not exceed TPERs.
APPEARED IN COMPLIANCE—Compliance was determined during the most recent permit review,
based on the sources operating as described. Sources are operated the same as during last permit
evaluation. Nothing indicates non-compliance.
B.6. G.S. 143-215.108(c)(1)—Facility-wide applicability. The facility shall be properly operated and
maintained at all times in a manner that will effect an overall reduction in air pollution. Unless
otherwise specified by this permit, no emission source may be operated without the concurrent
operation of its associated air cleaning device(s) and appurtenances.
APPEARED IN COMPLIANCE—The facility appeared clean and well maintained. The facility keeps
records of all housekeeping duties.
VIII. NON-COMPLIANCE HISTORY SINCE 2012:

15 Feb 2013 —NOD—late reporting
19 Dec 2013 —NOD—recordkeeping deficiencies
14 Feb 2014—NOD—late reporting
18 August 2014—NOV—late reporting
17 November 2014—CAI—NES1 AP 4Z Guidance
13 June 2016—NOD—GACT 7D Deficiencies
12 December 2017—NOV - GACT 7D Deficiencies
30 October 2019—NOV/NRE—GACT/71)Deficiencies, General Condition B6 Proper Operation
IX. 112R APPLICABILITY:
The facility does not store any of the listed 112(r)chemicals in amounts that exceed the threshold quantities.
Therefore,the facility is not required to maintain a written Risk Management Plan(RMP).
X. CONCLUSION/RECOMMENDATION:
On 07 September 2022, Smithfield Hog Production — Bladenboro Feed Mill APPEARED IN
COMPLIANCE with their current air permit as documented in section VII. Permit Stipulations.
Pink Sheet Items:
None
/SCA