AQ_F_0900066_20191015_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Fn
ille Regional Office
AIR QUALITY ld Hog Production-Bladenboro Feed Mill
lity ID 0900066
Inspection Report IPS:Bladen/017Date: 10/21/2019
Facility Data Permit Data
Smithfield Hog Production-Bladenboro Feed Mill 08155/R12255 Bryant Swamp Road 6/7/2018Bladenboro,NC 28320 2/28/2023Lat: 34d 33.1310m Long: 78d 49.7910m atus Synthetic MinorSIC:.2048/Prepared Feeds Nee ermStatus 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
Feedmill Manager General Manager- South Environmental Engineer NSPS: Subpart Dc
[phone] Central Region [phone]
Ext22013 [phone]
Compliance Data
Comments:
Inspection Date 10/15/2019
/,�/� r Inspector's Name Heather Carter
Inspector's Signature Operating Status Operating
Compliance Code Compliance- inspection
Action Code FCE
Date of Signature: /d lit /Jr On-Site Inspection Result Violation
Total Actual emissions in ONS/YEAR:
TSP SO2 NOX VOC CO PMIO * 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
12/12/2017 NOV 2D .0611 Monitoring Emissions from Other Sources 05/15/2018
12/12/2017 NOV 2D .1 I I 1 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
I. DMCTIONS:
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 transferred, via a pneumatic receiving system
controlled by a bagfilter, from the truck to the interior structure of the mill. 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 7D);
NESHAP 4Z, RICE (Reciprocating Internal Combustion Engines) (GACT 4Z); and NSPS De, New
Source Performance Standards for Small Boilers. The facility is Synthetic Minor for PM10.
IV. EMISSION SOURCES:
' .
Wvator Operation
Truck grain receiving pit,and soft Bagfilter
ES-001 ingredients pit CD-107 (850 square feet of filter area)
Operating w/No VE Operating w/No VE
Receiving turnhead negative air system Bag of
of
ES-002 Not Operating CD-123 (332 square feet filter area)
Not Operating
Bagfilter
ES-003 Receiving tumhead negative air system Not Operating CD-124 (209 square feet of filter area)
I Not Operating
Bagfilter
ES-004 Pneumatic receiving system CD-129 (200 square feet of filter area)
Not Operating
Not Operating
Pneumatic receiving system Bagfilter
ES-005 CD-133 (200 square feet of filter area)
Not On Site Not On Site

gj
Ground Bagfilter
grain negative air system
I ES- air Not Operating CD-218 � (300 square feet of filter area)
Not Operating
One (1) load-out system having twenty
S-016a
E (20)load-out bins N/A N/A
(NESHAP) I Operating w/No VE
One (1) load-out system having twenty
ES-016b ) (20) load-out bins -----�N/A N/A
(
NESHAP Operating w/No VE
Rail Car Receiving
ES-017 N/A N/A
Not Operating Y
Truck grain receiving pit, 15,000
j 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 j
ES-020b capacity N/A N/A
No Filling
Utility Operation
Emergency Generator,No. 2 fuel oil fired,
750 kW, Onan Model D970636382 and
ES-016 (Serial 86930A,with turbocharger and low N/A I N/A
(NESHAP) i 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
Operating on NG on low fire w/No VE
_ I
ES-013 Natural gas/No. 2 fuel oil-fired boiler
(NSPS) (20.925 mmBtu/hr maximum heat input) N/A N/A
On on NG on high fire with No VE
Feed Mill Operation
Hammer mill system Airlanco Model 100AST10-II
ES-007aT (capacity: 53 tons/hour) i Bagfilter !
Not Operating CD-212
— Hammer mills stem (1,640 sq. ft. of filter area)
i y Operating without Air Supply;
ES-007b (capacity: 53 tons/hour) No VE observed _
Operating _-_��
I_ _
Hammer mill system Airlanco Model 100AST10-II
CD-312
ES-008a (capacity: 53 tons/hour) Bagfilter
Operating (1,640 sq. ft. of filter area)

— — Em�sa�oTV 4
rtSa Cbx o> {,x04trol+System'
—too W
Aeseriph SyiuIDT it
e3enpho(k-
Hammer mill system Operating with No VE
ES-008b (capacity: 53 tons/hour)
Operating
Three(3) cyclones installed in
Pelleting system
ES-010 �� parallel
(capacity: 60 tons/hour) CD-M8
(NESHAP) ' (54 inches in diameter each)
Operating ? Operating with No VE
— —
Pelleting system
Three(3)cyclones installed inES-011 (capacity: 60 tons/hour) CD-608 parallel
j (54 inches in diameter each)
Not Operating
Not Operating
Pelleting system Three (3) cyclones installed in
ES-012 parallel
(capacity: 60 tons/hour) CD-708
(NESAAP) (54 inches in diameter each)
Operating
Operating with No VE
Mixed feed turnhead negative air system Bagfilter
ES-015 (209 square feet of(capacity:36 tons/hour) CD-422 filter area)
(NESHAP) iOperating Operating without Air Supply;
No VE observed
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 N/A N/A
Not Operating
V. INSIGNIFICANT EMISSION SOURCES:
" ' S of d rc40 lie
So to t= x{ Exe4t ul4t�op �
IES-101
Storage Silos 2Q .0102 (h)(5) No Yes
Sto ge S]os 2Q .0102 (h)(5) No Yes
Storage Silos 2Q .0102 (h)(5) No Yes
IES-104 2Q .0102 (h)(5) No Yes
Storage Silos j
IES-lOSa 2Q ,0102 (h)(5) No Yes
Storage Silos
IES-106 2Q .0102 (h)(5) No Yes
Storage Silos
IES-107
Storage Silos 2Q .0102 (h)(5) No Yes

IES-108 2Q .0102 (h)(5) No i Yes
Storage Silos
IES-022
2Q .0102�(h)(5) No Yes
Bagging Operation
IES-023 2Q .0102 (h)(5) No Yes
'Flat Storage Bagging System,
VI. INSPECTION SUMMARY:
On 15 October 2019, Jeffrey Nelson and I, both of FRO DAQ, conducted an air quality compliance
inspection of Smithfield Hog Production — Bladenboro Feed Mill. We met with Allen King, Feedmill
Manager and Greg Ewing, Regional Operations Manager. We discussed specific sources/operations we
wanted to see if they were operating while we were onsite, and we took a tour of the facility from start to
finish, receiving to feed loadout. During the tour we observed all the emission sources and all associated
control devices. We observed a lot of dust buildup throughout the whole facility, which was notably
worse and different from past inspections. During the inspection no VE were observed from any non-
fugitive emission source. However, during the tour we did noted several issues:
a) Bagfilters CD-422, installed on the Mixed Feed distribution system (ES-015), and CD-212,
installed on two Hammer Mills (ES-007a & b), were not operating as designed while the sources
were operating(no air supply to the units),
b) A large feed spill on the roof from ES-015 had not been cleaned up for weeks (this is subject to
NESAIR 7D housekeeping requirements as well as 2D .0540 fugitive dust rule),
c) A boiler replacement(of which DAQ was not notified) possibly a like-for-like replacement.
d) A change in how they receive the trace mineral which contains Manganese, which makes
additional facility locations subject to the housekeeping requirements.
e)Dust emissions from an Explosion Vent(at rooftop level)that was loose on a receiving leg.
We reviewed the FACFINDER information: updating the facility contact from Mitchell Batts to Allen
King, Feedmill Manager. We reviewed records for Inspection & Maintenance (I&M) on the bagfilters
and cyclones, and records for NESHAP 7D requirements. Mr. King was able to quickly provide the
records he had which was an improvement from past years. We made recommendations for
changes/additions in recordkeeping to improve the validity of the records for bagfilter and cyclone I&M.
The records for NESHAP 7D requirements were incomplete in two areas. The facility has not burned any
fuel other than Natural Gas in recent years, and have monthly fuel usage records accessible via the
Piedmont Natural Gas supplier website.
Production:
Year Feed Production t ) Grain Dried (t
2019 ( d) 530,253 12,927
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, which mean 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 Ibs 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
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. 21) .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)011 -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. Even with the discovery that two bagfilters were not being
operated as designed for short periods of time, the amount of increase particulate matter emissions
possible would not impact the facility's compliance with the overall allowable emission rate.
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/mrnBtu.
Appeared in Compliance - Facility records indicate exclusive use of natural gas in the boilers, with
use of low sulfur #2 fuel oil only when curtailed by gas company; exclusive use of natural gas in
dryer; and exclusive use of 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 0.0006 Ibs/mmBtu, and for No.
2 fuel oil is 0.51 Ib/mmBtu, both well below the limit. NOTE: the generator has not operated since
2017 as it is inoperable due to mechanical issues.
A.6. 2D .0521, "Control of Visible Emissions" All non-fugitive sources are subject.
Appeared in Compliance — We observed no VE from non-fugitive emission sources during the
inspection. There was a lot of dust buildup throughout the whole facility but nothing to indicate a
recurring VE problem with any one source.
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 3 July 2019, 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— No reports of excess emissions were made by the facility since the last
inspection. We observed several issues at the facility that may have or could have led to excess

emissions, but were not quantifiable. We educated Mr. King on the need to be aware of excess
emissions and notify this office if the situation occurs.
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 — We observed no indications of fugitive dust leaving the property
boundaries during this inspection. However, from the ground we did note that one of the receiving
legs had an explosion panel located near the rooftop that showed a fair amount of dust accumulation.
When we were on the roof we actually saw the panel lift and dust was blown all over us. The release
is small but appeared to be fairly regular, every time a truck is unloaded. We discussed the necessity
for leak and breakdowns to be repaired expeditiously. Mr. Ewing and Mr. King stated they would
have someone fix the panel within a day or two.
Mr. King stated that he has not received any dust complaints, and no dust complaints associated with
this facility have been received by DAQ since the last inspection. Mr. King was not aware of the
process the past managers had in place to record and address complaints if they are received. Mr.
Ewing stated he would advise him on the process and location of the forms.
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.
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 1 October 2019. In addition, the facility conducts daily visual inspections and records
the fan amperage on each cyclone set.
While the records were in good order, we noted that the records were not being completely filled out
by the persons doing the work. The records instruct the person conducting the work to initial each
item in the check list that is completed. That was not being done on any record for the past year.
Additionally, there were no records for the past year that showed any corrective action or comments
about the inspection. We advised Mr. King to improve 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.
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, however they appear to be hit or miss with that schedule. They do appear to
consistently conduct a quarterly inspection on each bag filter, and that inspection is commensurate
with the required annual internal inspection.
r Control, evide Last A(Ulual Igsliection '
CD-107 09/28/19
CD-123 06/28/19
CD-124 09/28/19
CD-129 09/2)8/19

CD-133 Removed in 2014
CD-218 09/28/19
CD-212 10/02/19
CD-312 10/02/19
CD-422 10/02/19
While the records were in good order, we noted that the records were not being completely filled out
by the persons doing the work. The records instruct the person conducting the work to initial each
item in the check list that is completed. That was not being done on any record for the past year.
Additionally, there were no records for the past year that showed any corrective action or comments
about the inspection. We advised Mr. King to improve 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.
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 I", submitting to the DAQ only if deviations have occurred.
Appeared in Violation — Monthly Housekeeping Requirement The whole facility had more dust
accumulation than seen in the past 10 +years. It was obvious from visual observations that
housekeeping activities were not meeting the requirement. Additionally, there was a large mixed feed
spill on the roof that had not been cleaned up for weeks. The records of housekeeping activities were
also incomplete. During the inspection we learned that the facility no longer receives the manganese
containing product in bags/totes, but instead now receives via truck in the receiving pit. This changes
means that additional areas of the facility are now subject to the housekeeping requirements. This
change was discussed with Mr. King and Mr. Ewing. They were advised that not only is their current
recordkeeping system not sufficient for demonstrating compliance with the housekeeping requirement
in the areas previously identified as subject,but that additional areas need to be covered now that they
receive the material via truck receiving (and it was indicated that they have been receiving this
material via ruck for quite a while,years).
Monthly Truck Load-out Sock Inspection Requirement Records appeared valid and complete. Socks
appeared a little wom, but still functional. Mr. King stated that new socks had been ordered, but had
not yet arrived for replacement.
Quarterly Cyclone Inspection Requirement Inspections are completed at least quarterly (some
monthly inspections are also completed). While the records were in good order, we noted that the
records were not being completely filled out by the persons doing the work. The records instruct the
person conducting the work to initial each item in the check list that is completed. That was not being
done on any record for the past year. Additionally, there were no records for the past year that
showed any corrective action or comments about the inspection. We advised Mr. King to improve
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.
Cyclone Visual Observation Requirement The facility records fan amperages on a daily basis, which
is an indicator on how the cyclone is operating; additionally, the facility has an automated 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 filled out the facility information on an ACC form, but he had
labeled it 2019 (vs 2018),had not marked whether the facility had been compliant or deficient for that

year, and admitted that he had not known what the form was and did not review any records prior to
filling out the basic facility info on the form. Mr. King was advised to review the requirements of the
NESHAP and his 2018 records and then complete the ACC and send to the FRO as well as keep on
site.
A.13. 2D .1111, Reciprocating Internal Combustion Engine NESIIAP (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 — We detected no odors off-site when entering and departing the facility.
Mr. King stated that the facility has received no complaints, and no complaints have been received in
the FRO DAQ. Mr. King was not aware of the process the past managers had in place to record and
address complaints if they are received. Mr. Ewing stated he would advise him on the process and
location of the forms.
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 2018. Data for 2019 (ytd) also indicates they will be well below the limits:
530,253 tons feed produced and 12,927 tons grain dried.
A.16. 2Q .0317, Avoidance of Boiler NESHAP (GACT 6J)- 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.
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 Violation — We observed two (2) bagfilters that were not being properly operated and
maintained while the associated sources were operating: CD-422, installed on the Mixed Feed
distribution system (ES-0 15), 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) at the time of inspection. And both
emission sources were in operation at the time of inspection and it appears they had been for the
length of time the air supply had been cut off.
Mr. King investigated CD-422 and found that the air supply was just turned off, so he turned it back
on. He stated that CD-422 had been repaired and that when the work was completed the personnel
probably just forgot to turn the air supply back on. I asked how long it was turned off and he stated
for no more than two or three days.
For CD-212 the air supply line had been completely disconnected. There was a solenoid valve or
something wrong and personnel had identified the problem but not fixed it so they disconnected the
line in the interim. When Mr. King investigated he found it and called maintenance to come repair.
He did not know how long that device had been without air.
Additionally, the dust explosion vent on the receiving leg had been loose and emitting dust,
uncontrolled, into the atmosphere for a significant amount of time due to the amount of particulate
buildup observed on the surface area surrounding the vent. Similarly, the feed mash spill on the roof
had not been cleaned up for a significant amount of time, per a statement from Mr. King. This
material was observed to have migrated to the edges of the roof, and indications are that it also was
being blown into the atmosphere uncontrolled. While equipment does break, repairs are to be made
promptly to ensure the facility is properly operated and maintained.
VIII. 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
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 15 October 2019, Smithfield Hog Production — Bladenboro Feed Mill appeared to be operating in
violation of their current air permit as documented in section VII. Permit Stipulations.
I recommend issuing a Notice of Violation/Notice of Recommendation for Enforcement(NOV/NRE)for
failure to comply with all the required housekeeping activities,recordkeeping and reporting under 15A
NCAC 02D .I 111, Prepared Feeds Manufacturing NESHAP (GACT 7D) and for improper operation and
maintenance of bag filters and sources of particulate emissions under G.S. 143-215.108(c)(1).

Pink Sheet Items:
1) Include additional language to Syn Minor Condition:
Operations Restrictions
i. Particulate matter emissions shall be controlled as described in the permitted equipment list.
ii. The Permittee shall perform periodic inspections and maintenance of fabric filters, cyclones,
and multicyclones as required in the 15A NCAC 2C .0611 "Fabric Filter Requirements",
"Cyclone Requirements", and "Multicyclone Requirements" permit conditions.
Recordkeeping Requirements
i. The Permittee shall maintain records of the periodic inspection and maintenance of the
fabric filters, cyclones, and multicyclones as required in the 15A NCAC 2D .0611 "Fabric
Filter Requirements", "Cyclone Requirements", and "Multicyclone Requirements" permit
conditions.
2) New boiler installed at the facility, like-for-like replacement for boiler ES-013. The new boiler's
name plate showed it as a 2019 Cleaver Brooks rated at 20.412 mmBtu max heat input and can
burn NG or TO.
3) Update Emission Source Table to include additional sources subject to the NESHAP 71): Truck
Receiving Pit(ES-001), Receiving Turnheads(ES-002 & 003)
/HSC