Loading...
HomeMy WebLinkAboutAQ_F_0900066_20210210_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: 02/22/2021 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 Allen King John Sargent Katie Elmer MACT Part 63: Subpart 7D, Subpart ZZZZ NSPS: Subpart Dc Feedmill Manager General Manager- South Environmental Project (910)863-2397 Central Region Manager (910)296-3768 (910)293-5245 Compliance Data Comments: Inspection Date 02/10/2021 _ Inspector's Name Stephen Allen Inspector's Signature: Operating Status Operating Compliance Status Compliance-inspection Action Code FCE Date of Signature: G Z(z 2 /2 , Inspection Result Compliance Total Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PM10 *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(in pounds) Five Year Violation History: Date Letter TVPe 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 2D A I I I 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 Smithfield Hog Production—Bladenboro Feed Mill Compliance Inspection Report Page 2 of 10 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 420 (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 71), Prepared Feeds Manufacturing (GACT 713); NESHAP 4Z,RICE(Reciprocating Internal Combustion Engines)(GACT 4Z);and NSPS Dc,New Source Performance Standards for Small Boilers. The facility is Synthetic Minor for PM10. IV. EMISSION SOURCES: MMMM M—ENNEREEM aC+itewabrw� � Truck grain receiving pit,and soft Bagfilter ES-001 ingredients pit CD-107 (850 square feet of filter area) Not operating I Operating w/No VE Smithfield Hog Production—Bladenboro Feed Mill Compliance Inspection Report Page 3 of 10 Receiving turnhead negative air system Bagfilter ES-002 Not Operating CD-123 (332 square feet of filter area) Not Operating Receiving turnhead negative air system Bagfilter ES-003 Not or CD-124 (209 square feet of filter area) Not Operating Pneumatic receiving system Bagfilter ES-004 Not Operating Not (200 square feet of filter area) Not Operating Bagfilter. ES-005 Pneumatic receiving system CD-133 (200 square feet of filter area) Not On Site Not On Site i Bagfilter ES-009 Ground grain negative air system CD-218 (300 square feet of filter area) Not Operating Not Operating I ES-016a One(1) load-out system having twenty (NESHAP) (20) load-out bins N/A N/A Operating with 0% opacity ES-016b One(1) load-out system having twenty (20)load-out bins N/A N/A (NESHAP) Operating with 00yo opacity Rail Car Receiving N/A N/A ES-017 Operating with<5% opacity Truck grain receiving pit, 15,000 ES-018 bushels/hr max throughput,with partially N/A N/A enclosed shelter Not Operating Wet grain storage silo, 55,000 bushels ES-020a capacity N/A N/A No Filling Wet grain storage silo, 55,000 bushels ES-020b capacity N/A N/A No Filling tiuty Ope rirtion Emergency Generator,No. 2 fuel oil Fred, 750 kW, Onan Model D970636382 and ES-0 Seria186930A,with turbocharger and low N/A N/A (NESHAP) temperature aftercooler control devices. Not Operating Smithfield Hog Production—Bladenboro Feed Mill Compliance Inspection Report Page 4 of 10 iv s Natural gas/No. 2 fuel oil-fired boiler ES-014 (20.925 mmBtu/hr maximum heat input) (NSPS) Replaced with 20.4 mmBtu NG/FO boiler N/A N/A Operation with 0% opacity ES-013 Natural gas/No. 2 fuel oil-fired boiler j (NSPS) (20.925 mmBtu/hr maximum heat input) N/A N/A Operation with 0% opacity Feed Mi11:OperatitYtt Hammer mill system ES-007a (capacity: 53 tons/hour) Airlanco Model 100AST10 II Operating CD-212 Bagfilter (1,640 sq. ft. of filter area) Hammer mill system Operating without Air Supply; ES-007b (capacity: 53 tons/hour) Operation with 0% opacity Operating Hammer mill system ES-008a (capacity: 53 tons/hour) Airlanco Model 100AST10-II { Operating CD-312 Bagfilter Illlll Hammer mill system (1,640 sq. ft. of filter area) ES-008b (capacity: 53 tons/hour) Operation with 0% opacity Operating Pelleting system Three(3)cyclones installed in ES-010 parallel (capacity: 60 tons/hour) CD-508 (NESHAP) Operating (54 inches in diameter each) Operation with 0% opacity Pelleting system Three(3)cyclones installed in ES-0I I (capacity: 60 tons/hour) CD-608 parallel (NESHAP) (54 inches in diameter each) Operating Operation with 0% opacity Pelleting system Three(3)cyclones installed in ES-012 (capacity: 60 tons/hour) CD-708 parallel (NESHAP) Operating (54 inches in diameter each) Operation with 0% opacity Mixed feed tumbead negative air system Bagfilter ES-015 (capacity:36 tons/hour) CD-422 (209 square feet of filter area) (NESHAP) Operating Operating without Air Supply; Operation with 0% opacity Natural gas-fired grain dryer ES-019 47.8 mmBtu/hr maximum heat input N/A N/A Not Operating ES-021 Grain dryer truck loadom N/A N/A Not Operating I II! Smithfield Hog Production—Bladenboro Feed Mill Compliance Inspection Report Page 5 of 10 V. INSIGNIFICANT EMISSION SOURCES: IES-101 2Q .0102 (h)(5) No Yes Storage Silos IES-102 2Q .0102(h)(5) No Yes Storage Silos IES-103 2Q .0102(h)(5) No Yes Storage Silos IES-104 2Q .0102 (h)(5) No Yes Storage Silos IES-105a 2Q .0102 (h)(5) No Yes Storage Silos IES-106 2Q .0102 (h)(5) No Yes Storage Silos IES-107 2Q .0102 (h)(5) No Yes Storage Silos IES-108 2Q .0102 (h)(5) No Yes Storage Silos IES-022 2Q .0102 (h)(5) No Yes Bagging Operation IES-023 2Q .0102 (h)(5) No Yes Flat Storage Bagging SystemF -F VI. INSPECTION SUMMARY: On 10 February 2021, I, Stephen Allen of FRO DAQ, conducted an air quality compliance inspection of Smithfield Hog Production — Bladenboro Feed Mill. I met with Allen King, Feedmill Manager, Greg Ewing,Regional Operations Manager, and Rob Richardson, Environmental Resource Specialist. Mr. King reviewed the FACFINDER information and did not note any changes. I reviewed records for Inspection & Maintenance (I&M) on the bagfilters and cyclones, and records for NESHAP 7D requirements. Mr. King has all of the records for the facility in two large binders. Mr. King has updated some of the housecleaning checklists and inspection/maintenance records for the bagfilters based on recommendations and deficiencies noted during the previous inspection. Housekeeping records include inspecting/cleaning the roof area where an accumulation of spilled feed was discovered during the previous inspection. Cyclone and bagfilter records now include comments on repairs and maintenance,which were lacking during the previous inspection. The facility was previously cited for dust accumulations throughout the facility. Mr.King stated they have addressed all of the housekeeping issued discovered during the previous inspection. Mr. King and Mr. Ewing stated that the facility has gone back to using bags of trace minerals instead of receiving it in the truck receiving pit. Mr. King stated they switched to bags shortly after they were cited in the previous inspection. Smithfield Hog Production—Bladenboro Feed Mill Compliance Inspection Report Page 6 of 10 We toured the facility,which was operating during the inspection. We began at the rail receiving pit where a load of corn was being received. I observed brief fugitive emissions<5% opacity that did not leave the enclosed receiving area. I observed the boilers operating on natural gas with 0% opacity. Mr. King and I then went through the permit and observed each of the bagfilters operating with 0%opacity. The air supply and pulse were functioning on all of the bagfilters. Mr.King stated the issues observed during the previous inspection were quickly repaired.I went through the previous inspection report and NOV with Mr. King as we toured the facility and he pointed out each of the areas that were cited during the inspection. The housekeeping issues observed appear to have been addressed and the facility no longer receives trace minerals in the truck receiving area. The area where the trace minerals are stored and dispensed appear to be clean and well maintained. Production: tXear.',r ° :FeQd,. u,�iipit• GiainD'' t ' ;�_ 2020 726,714 45,749 2019( d) 693,794 18'278 2018 665,974 19,301 2017 678,789 24,037 2016 693,754 18,278 VIL 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. 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 bumed any fuel other than NG since the previous inspection. AP-42 PM emission factor for 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/mntBtu. APPEARED IN COMPLIANCE-Facility records indicate exclusive use of natural gas in the boilers, with use of ultra-low sulfur#2 fuel oil only when curtailed by gas company; exclusive use of natural Smithfield Hog Production—Bladenboro Feed Mill Compliance Inspection Report Page 7 of 10 gas in dryer; and exclusive use of ultra-low sulfur fuel oil in the generator. The facility has not used fuel oil in the boilers since 2005. AP-42 S02 emissions factor for natural gas is 0.00061bs/mmBtu,and for No. 2 fuel oil is 0.002 Ib/mmBtu, both well below the limit. The emergency generator has not operated since 2017 as it is inoperable due to mechanical issues. A.6. 2D .0521,"Control of Visible Emissions"—The Permittee shall not cause or allow fugitive dust emissions to cause or contribute to complaints or excess visible emissions beyond the property boundary. APPEARED IN COMPLIANCE — I observed no visible emissions from non-fugitive emission sources during the inspection. The issues observed during the previous inspection appear to have been addressed by the facility. 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 30 December 2020, 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 COMPLLANCE— Mr.King stated that there have been no excess emissions events since the last inspection. I 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 the property boundaries. APPEARED IN COMPLIANCE — Mr. King 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 18 January 2021. In addition,the facility conducts daily visual inspections and records the fan amperage on each cyclone set. Mr. King and the facility have improved the validity of the records by having the employee indicate what actions were completed in the checklist for each inspection, as well as write comments or corrective actions as applicable. Smithfield Hog Production—Bladenboro Feed Mill Compliance Inspection Report Page 8 of 10 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 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 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. CD-107 12/24/20 CD-123 12/1/20 CD-124 12/28/20 CD-129 12/24/20 CD-133 Removed in 2014 CD-218 12/24/20 CD-212 10/22/2020 CD-312 1/18/21 CD-422 10/22/20 Mr. King and the facility employees conducting the inspections have improved the validity of the records by having the employee indicate what actions were completed in the checklist for each inspection,as well as write comments or corrective actions as applicable. Deficiencies in this area were noted in the previous inspection. 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 V, submitting to the DAQ only if deviations have occurred. APPEARED IN COMPLIANCE—Monthly Housekeeping Requirement: The facility was cited in the last inspection for deficiencies in the monthly housekeeping requirements. During the previous inspection it was noted that the facility no longer was receiving the manganese containing product in bags/totes, but instead was receiving via truck in the receiving pit. This change meant that additional areas of the facility were subject to the housekeeping requirements. The facility switched to receiving. trace minerals in bags after the previous inspection and added more areas to the housekeeping list to ensure the proper areas were being cleaned or at least visually inspected. This includes the rooftop area where a large spill was observed during the previous inspection.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. Smithfield Hog Production—Bladenboro Feed Mill Compliance Inspection Report Page 9 of 10 Quarterly Cyclone Inspection Requirement: Inspections are completed at least quarterly (some monthly inspections are also completed). Mr. King has improved the records since the previous inspection by having the employee indicate what actions were completed in the checklist for each inspection, as well as write comments or corrective actions when repairs or maintenance occurred. 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. King had the 2020 ACC form dated 28 February 2021 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.King 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 — I detected no odors off-site when entering and departing the facility. Mr.King 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: PM10 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 2020. Data for 2020(ytd)also indicates they will be well below the limits: 776,714 tons feed produced and 45,749 tons grain dried. A.16. 2Q .0317, Avoidance of Boiler NESHAP (GACT 6.I)- 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 .0711, "Toxic Air Pollutant Emissions Limitation"- Facility-wide applicability. Facility-wide emissions shall not exceed TPERs. Smithfield Hog Production—Bladenboro Feed Mill Compliance Inspection Report Page 10 of 10 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 — During the previous inspection the facility was cited for not properly operating and maintaining bagfilters when the sources were operating. Two bagfilters had no air supply to the units. Mr. King stated that repairs had been made to all bagfilters and the dust explosion vent that was a source of fugitive dust emissions during the previous inspection. I observed all bagfilters operating with 0% opacity and with proper air pulses during the inspection. Overall, the facility appeared clean and well maintained. The facility has added inspecting/sweeping the roof to the housekeeping duties that are required weekly after a heavy dust buildup was observed during the previous inspection. VHI. NON-COMPLIANCE HISTORY SINCE 2010: 08 August 2011 —CAI—late reporting 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—NESHAP 4Z Guidance 13 June 2016—NOD—GACT 7D Deficiencies 12 December 2017—NOV-GACT 7D Deficiencies 30 October 2019—NOV/NRE—GACT/71)Deficiciencies, General Condition 136 Proper Operation IX. 112R APPLICABH,ITY: 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 10 February 2021, 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