AQ_F_0900066_20200302_ENF_Enf-FND

STATE OF NORTH CAROLINA NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL
COUNTY OF SAMPSON QUALITY
IN THE MATTER OF: ) CASE NUMBER 2019-091
SMITHFIELD HOG PRODUCTION —)
BLADENBORO FEED MILL )
FOR VIOLATION OF: ) CIVIL PENALTY ASSESSMENT
15A NCAC 02D .1111 - GENERALLY)
AVAILABLE CONTROL TECHNOLOGY)
(GACT 7D) )
GENERAL CONDITION B.6, )
G.S. 143-215.108(c)(1) )
Acting pursuant to North Carolina General Statutes (G.S.) 143-215.114A, I, Michael A.
Abraczinskas, Director of the Division of Air Quality(DAQ),make the following:
I. FINDINGS OF FACT:
A. Smithfield Hog Production- Bladenboro Feed Mill (Bladenboro Feed Mill),located near
Bladenboro, in Bladen County,North Carolina, is an animal feed manufacturing mill.
Bladenboro Feed Mill operates under Air Permit No. 08155R12, issued 7 June 2018, and
expiring 28 February 2023. Bladenboro Feed Mill is subject to the National Emission
Standards for Hazardous Air Pollutants (NESHAP) Subpart 7D, Prepared Feeds
Manufacturing. The facility is classified as a synthetic minor facility for PMio.
B. On 15 October 2019, Jeffrey Nelson and Heather Carter,both with the Fayetteville
Regional Office Division of Air Quality(FRO DAQ), conducted an air quality
compliance inspection at the Bladenboro Feed Mill facility. The inspectors met with
Mr. Allen King, Feedmill Manager, and Mr. Greg Ewing, Regional Operations Manager.
During the inspection violations of 15A NCAC 02D .I 111, "Generally Available
Control Technology" - Area Source Standards for Prepared Feeds Manufacturing
(GACT 7D) and General Condition B.6 were documented.
C. The current permit No. 08155R12 includes Specific Condition and Limitation A.12, 15A
NCAC 02D .1111, "Generally Available Control Technology" -Area Source Standards
for Prepared Feeds Manufacturing(GACT 7D), which contains the following
requirements:
• Specific Condition and Limitation A.12.(b.)(i.) specifies, in part, "You shall perform
housekeeping measures to minimize excess dust... " including "You shall use either
an industrial vacuum system or manual sweeping to reduce the amount of dust"
Visibly there was a significant increase in the dust buildup throughout the facility
since the previous inspection (and as compared to a number of previous years).

Smithfield Hog Production-Bladenboro Feed Mill
DAQ Case No. 2019-091
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Additional areas of the facility were discovered to be subject to this requirement (i.e.
receiving and receiving turnhead areas) and have not been part of the housekeeping
activities and are significant sources of excess dust containing Manganese. During
the inspection a significant spill of mixed feed was observed on the roof and Mr.
King stated that it had occurred about a week prior. The length of time the mixed
feed spill remained on the roof is another clear indication that the work practice
standard of minimizing excess dust has not been achieved.
• Specific Condition and Limitation A.12.(c.)(iii.) specifies, "The monthly
housekeeping requirement (dusting and sweeping/vacuuming) shall be tracked and
dated in a logbook to be maintained on site at all times. " Records were incomplete
as they did not address all subject areas of the facility. Additionally, some records
were simply inspections, and not really records of housekeeping activities completed
on specified dates, as required.
• Specific Condition and Limitation A.12.(e.)(iv.) stipulates, in part, "An annual
compliance certification report shall be prepared each year by March 1 for the
previous year containing the information specified... " "You shall submit the report
to NC DAQ if you had any..." deviations. The 2018 ACC was not completed in
accordance with the rule by March 1, 2019. The document on file was labeled for
the wrong year and did not have a compliance statement indicated. Mr. King
admitted that he had no idea what the document was for, that he just filled in the
blanks best he could and put it in the book. Since there were deviations from the
requirements of the rule during CY 2018, the 2018 ACC should also have been
submitted to the FRO DAQ.
D. The current permit No. 08155R12 includes General Condition B.6, which requires that:
"...In accordance with G.S. 143-215.108(c)(1), 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... "
During the inspection two (2)bagfilters were observed that were not being properly
operated and maintained while the associated sources were operating: CD-422, installed
on the Mixed Feed distribution system(ES-015), and CD-212, installed on two Hammer
Mills (ES-007a&b). Each bag filter had no air supply to the unit(for the cleaning
mechanism) while the sources were operating. Mr. King stated that CD-422 had been
without air supply for at least 2-3 days and he did not know how long CD-212 had been
operating without air supply.
E. On 30 October 2019, the FRO DAQ issued a Notice of Violation/Notice of
Recommendation of Enforcement(NOWNRE)to Smithfield Hog Production-
Bladenboro Feed Mill for the observed and documented violations.
F. FRO DAQ received a response to the NOV/NRE from Smithfield Hog Production-
Bladenboro Feed Mill on 18 November 2019.

Smithfield Hog Production-Bladenboro Feed Mill
DAQ Case No. 2019-091
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G. Prior Air Quality Compliance History:
13 June 2016 NOD—NESHAP 7D—Missing 2015 ACC
12 Dec 2017 NOV—NESHAP 7D monitoring&recordkeeping(Cyclones),
2Q .0315 limit exceeded(actual emissions didn't exceed TV),
2D .0611 monitoring and recordkeeping(bag houses)
H. The cost of investigation in this matter totaled $398.
Based upon the above Findings of Fact, I make the following:
II. CONCLUSIONS OF LAW:
A. Smithfield Hog Production- Bladenboro Feed Mill was in violation of 15A NCAC
02D .1111 "Generally Available Control Technology" -Area Source Standards for
Prepared Feeds Manufacturing(GACT 7D) for failure to monitor,record and report
as required.
B. Smithfield Hog Production- Bladenboro Feed Mill was in violation of permit
General Condition B.6 and G.S. 143-215.108(c)(1) for failure to properly operate
bag houses CD-422 and CD-212 in a manner that will effect an overall reduction in
air pollution.
C. G.S. 143-215.114A provides that a civil penalty of not more than twenty-five
thousand dollars per violation may be assessed against a person who violates or fails
to act in accordance with the terms, conditions, or requirements of a permit required
by NCGS 143-215.108 or who violates any regulation adopted by the Environmental
Management Commission.
D. G.S. 143-215.3(a)(9)provides that the costs of any investigation or inspection may
be assessed against a person who violates or fails to act in accordance with the terms,
conditions, or requirements of a permit required by G.S. 143-215.108 or who
violates any regulation adopted by the Environmental Management Commission.

Smithfield Hog Production- Bladenboro Feed Mill
DAQ Case No. 2019-091
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Based upon the above Findings of Fact and Conclusions of Law, I make the following:
III. DECISION:
Smithfield Hog Production- Bladenboro Feed Mill is hereby assessed a civil penalty of
$ Z,00b . yo For three(3) violations of 15A NCAC 02D .I I I "Generally
Available Control Technology" -Area Source Standards for
Prepared Feeds Manufacturing(GACT 7D) for failure to monitor,
record, and report as required.
vv For one (1)violation of permit General Condition B.6 and G.S.
143-215.108(c)(1) for failure to properly operate bag houses CD-
422 and CD-212 in a manner that will effect an overall reduction in
air pollution.
$ 3 f o 00. va TOTAL CIVIL PENALTY, which is 3 percent of the
maximum penalty authorized by G.S. 143-215.114A.
$ 398 Investigation costs.
R • n o TOTAL AMOUNT DUE.
Pursuant to G.S. 143-215.114A in determining the amount of the penalty, I considered the
factors listed in G.S. 143B-282.1(b) and 15A NCAC 2J .0106, which are the following:
1) The degree and extent of harm to the natural resources of the State,to the public
health, or to private property resulting from the violation(s);
2) The duration and gravity of the violation(s);
3) The effect on ground or surface water quantity or quality or on air quality;
4) The cost of rectifying the damage;
5) The amount of money saved by noncompliance;
6) Whether the violation was committed willfully or intentionally;
7) The prior record of the violator in complying or failing to comply with programs over
which the Environmental Management Commission has regulatory authority; and
8) The cost to the State of the enforcement procedures.
3 Al/zo
Date Michael A. Abraczinskas, Direct
Division of Air Quality