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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 acxliH eawuw, °u° � 910.433.3300 T 1910.485.7467 F 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 .rarounw '� 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 scum cnr,"°;nun 910.433.3300 T 1910.485.7467 F