HomeMy WebLinkAboutAQ_F_0900066_20191030_CMPL_NOV-NRE MF
ROY COOPER °ws '
Governor
MICHAEL S. REGAN
Secretary
MICHAEL A.ABRACZINSKAS NORTH CAROLINA
Director Environmental Quality
30 October 2019
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. John Sargent, Vice President
Murphy-Brown, LLC
PO Box 759
Rose Hill,NC 28458
SUBJECT: Notice of Violation/Notice of Recommendation for Enforcement
15A NCAC 02D .1111,Prepared Feeds Manufacturing NESHAP (GACT 7D)
General Condition B.6 -G.S. 143-215.108(c)(1)Proper Operation
Smithfield Hog Production - Bladenboro Feed Mill Permit No. 08155RI2
Bladenboro,NC, Bladen County Facility ID: 06/09-00066
Fee Class: Synthetic Minor
Dear Mr. Sargent:
On 15 October 2019, Mr. Jeffrey Nelson and I met with Mr. Allen King, Feedmill Manager,
and Greg Ewing, Regional Operations Manager to conduct a full air quality compliance inspection of
the Smithfield Hog Production — Bladenboro Feed Mill facility in Bladenboro, Bladen County, NC.
We conducted a full facility tour and thorough records review with the following observations:
general housekeeping was poor throughout the facility, the housekeeping records required by the
Prepared Feeds Manufacturing NESHAP (GACT 7D) were not complete and new areas of the
facility requiring this work practice standard had been introduced with a change in receiving that was
not communicated with this office, the 2018 Annual Compliance Certification for GACT 7D was not
completed as required, and bagfilters and sources of particulate matter were being improperly
operated and maintained. The following violations of the current air permit and applicable rules
were documented:
1. 15A NCAC 2D .1111, "Generally Available Control Technology" - Area Source
Standards for Prepared Feeds Manufacturing (GACT 7D)
Specific Condition and Limitation A.12.(b.) stipulates, "The affected source is the
collection of all equipment and activities necessary to produce animal feed from the point
in the process where a material containing [Chromium] Cr or [Manganese] Mn is added,
to the point where the finished animal feed product leaves the facility." During the
inspection we learned that Manganese is introduced into the facility at the truck receiving
pit (ES-001), whereas previously it had been communicated that it was received in
bags/totes and introduced later in the process just prior to mixing. The housekeeping
requirements apply to additional areas of the facility with that change.
Specific Condition and Limitation A.12.(b.)(i.) specifies, in part, "You shall perform
housekeeping measures to minimize excess dust..." including "At least once per month,
�� North Carolina Department of Environmental Quality I Division of Air Quality
�' _ Fayetteville Regional Office 1 225 Green Street,Suite 7141 Fayetteville,North Carolina 28301
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Smithfield Hog Production—Bladenboro Feed Mill
30 October 2019
Page 2
you shall remove dust from walls, ledges, and equipment using low pressure air or by
other means, and then sweep or vacuum the area." 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). 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. Some of the
additional areas of the facility that we just discovered are subject to this requirement (i.e.
receiving turnheads areas) have not historically been part of the housekeeping activities
and are significant sources of excess dust containing Manganese.
Specific Condition and Limitation A.12.(c.) specifies that these housekeeping activities
shall be recorded in a logbook maintained on site. 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 what date.
Specific Condition and Limitation A.12.(e.)(iv.) stipulates that "An annual compliance
certification report shall be prepared each year by March 1 for the previous year
containing the information specified..." The 2018 ACC was not completed in
accordance with the rule by March 1, 2019.
Therefore, by failing to conduct the required housekeeping activities, failing to
record the activities and failing to prepare the 2018 ACC as required, you violated
15A NCAC 2D .1111, "Generally Available Control Technology" - Area Source
Standards for Prepared Feeds Manufacturing(GACT 7D).
2. General Condition B.6 -G.S. 143-215.108(c)(1) Proper Operation
General Condition B.6 stipulates that "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 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-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.
A dust explosion vent on the receiving leg was also observed as loose and emitting dust,
uncontrolled, into the atmosphere. Indications are that this has been occurring for a
significant amount of time due to the amount of particulate buildup observed on the
surface area surrounding the vent.
Therefore, by failing to properly operate and maintain your sources of and controls
for particulate emissions, you violated General Condition B.6 - G.S. 143-
215.108(c)(1).
North Carolina Department of Environmental Quality I Division of Air Quality
rvou., Fayetteville Regional Office 1 225 Green Street,Suite 7141 Fayetteville.North Carolina 28301
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910,433.3300 T 1910.485.7467F
Smithfield Hog Production—Bladenboro Feed Mill
30 October 2019
Page 3
As stated in the "subject" above, this letter represents not only a Notice of Violation for the
above-cited violations, but puts you on notice that this office is preparing an enforcement report
addressing the violations. The above violations and any future violation of an air quality regulation
are subject to the assessment of civil penalties per North Carolina General Statute 143-215.114A.
This General Statute provides that civil penalties of not more than twenty-five thousand dollars
($25,000) may be assessed against any person who violates any classification, standard, or limitation
established pursuant to General Statute 143-215.107, "Air Quality Standards and Classifications." In
addition, each day of continuing violation after written notification from the Division of Air Quality
may be considered a separate offense.
Please provide to this office as soon as possible, but no later than 15 November 2019, a
written response detailing: 1) the reasons for violating the above-mentioned permit requirements,
2) the steps that you plan to take or have taken to return to compliance, and 3) any additional
information or description of any mitigating circumstances in reference to the violations. After the
above date, in lieu of any mitigating circumstances brought to our attention,this office will submit an
enforcement report to the Director of the Division of Air Quality, including recommendations for the
assessment of appropriate civil penalties. Be advised that neither this letter, nor any subsequent
action, absolve you from responsibility for any violation or damage to public or private property or
from any enforcement action available to this agency.
Please note that violations of the Prepared Feeds Manufacturing NESHAP (GACT 7D) must
be reported in the facility's Annual Compliance Certification (ACC) report for 2019, which must be
postmarked for submittal to the FRO DAQ on or before 1 March 2020.
We strongly recommend that you carefully read and understand the requirements in your
current air permit. If you have any questions regarding your permit or the cited violations,please call
Greg Reeves, Permit Coordinator, or me, at 910-433-3300.
Sincerely,
"'�����
Heather S. Carter
Regional Supervisor
NCDEQ, Division of Air Quality
HSC
cc: FRO Facility Files
FRO Enforcement Files
North Carolina Department of Environmental Quality I Division of Air Quality
Fayetteville Regional Office 1 225 Green Street,Suite 7141 Fayetteville,North Carolina 28301
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910.433.3300 T 1910.485.7467 F