Document KJXb5yZVNYX42x5X0YVgJNkOQ
ft r:DA UModSWs
01:17'\= : - ' -
Region 6 Compliance Assurance and Enforcement Division
INSPECTION REPORT
Inspection Date(s): Media: Regulatory Program(s)
05/23/2017 EPCRA Section 313- Toxic Release Inventory Reporting
Company Name: Facility Name: Facility Physical Location :
Mailing add ress:
County/Parish: Website: Facility Contact:
Land O' Lakes
Land O' Lakes Purina Feed LLC - Shreveport
223 West 63rd Street
Shreveport, LA 71106
P.O. Box 6637
Shreveport, LA 71106
Caddo Parish
www.purinamills.com Billy Gueringer btgueringer@landolakes.com
I Regional EH&S Manager
FRS Number: TRI Facility ID .Number: NAICS:
110000450235 7 1106PRNML223WE 311119- Other Animal Food Manufacturing
Personnel participating in the inspection:
Billy Gueringer
Land O' Lakes
Todd Kennedy
Purina Animal Nutrition LLC
Jennifer Hines
Purina Animal Nutrition LLC
Regional EH&S Manager Senior Plant Manager Quality & Safety Supervisor
(254) 722-6632
(318) 671-6362
-
EPA Lead Inspector Signature/ Date
p~~
David Riley
'--'
-=!-jlo(, 1-
Date '
Supervisor Signature/Date
~ ..
Troy Stuckey V
7{<o{\7
Date
6ENFORM-019-R7 (2/15/2017)
1
Section I - INTRODUCTION
Land O'Lakes Purina Feed LLC- Shreveport Inspection Date: 05/23/2017
PURPOSE OF THE INSPECTION
The purpose of this inspection is to evaluate compliance with Section 313 of the Emergency Planning & Community Right-to-Know Act (EPCRA) for the Land O'Lakes Purina Feed LLCShreveport facility located at 223 West 53rct Street, Shreveport, Louisiana, 71106. The EPCRA 313 program has not been delegated to any state, so compliance inspections are conducted by the EPA. While the Louisiana Department of Environmental Quality was notified of the inspection, a representative did not attend.
The inspection covered the 2011 through 2015 calendar years and was initiated following a review of the facility's reporting history in the Toxic Release Inventory (TRI) database, which is the repository for reports submitted pursuant to EPCRA 313. There are three criteria that a facility must meet in order to be subject to reporting under EPCRA 313:
1. The facility has 10 full-time employees or the equivalent of 20,000 hours worked by all full time, part-time, and contract employees in that year
2. The facility is in a covered primary North American Industry Classification System (NAICS) code.
3. The facility manufactures, processes, or otherwise uses any listed toxic chemical above a specified threshold amount in a calendar year.
I arrived at the Land O'Lakes Purina Feed facility at !O:OOam on May 23, 2017, for an announced inspection. I met with Billy Gueringer, Regional Environmental, Health, & Safety Manager; Todd Kennedy, Plant Manager; and Jennifer Hines, Quality & Safety Supervisor. I presented my EPA enforcement credentials to those individuals present and informed them that the scope of the inspection would involve a review of the facility's manufacturing process, its annual usage of reportable toxic chemicals, and any releases, transfers, or other waste management of those chemicals. Mr. Kennedy's business card is in Appendix 1.
FACILITY DESCRIPTION The facility was built in 1953 by Ralston Purina for the manufacturing of livestock feed. In the late 1970s, manufacturing was split into pet food (Ralston) and livestock feed (Purina Mills), with this facility continuing to operate under the Purina Mills name. Purina Mills has had several owners since that time and was most recently purchased by Land O'Lakes in 2001. Currently, the company is designated as Purina Animal Nutrition LLC, a Division of Land O'Lakes. A facility map is contained in Appendix 2.
The facility is in NAICS code 311119 (Other Animal Food Manufacturing), which is a covered code for TRI reporting. The facility makes feed for beef & dairy cattle, horses, poultry, and other livestock. Raw materials such as wheat, soybean, and cottonseed byproducts; oats; grain; and
2
Land O'Lakes Purina Feed LLC- Shreveport Inspection Date: 05/23/2017
microingredients are received via truck and rail. They are ground, mixed, and formed into meal or pellets. Afterward, they are bagged or bulk loaded, and are distributed by truck. A process flow diagram is contained in Appendix 3.
Total operating hours is approximately 6,500 per year, yielding 135,000 tons of feed annually. The facility currently employs 48 people.
Section II - OBSERVATIONS
CHEMICALS SUBMITTED TO THE TRI DATABASE
For reporting years 2011, 2012, 2014, and 2015, the facility filed Form A certification statements for the TRI chemical categories copper compounds, manganese compounds, and/or zinc compounds (no forms were filed for 2013). Compounds in these categories are processed as microingredients for feed, and the annual reporting threshold for each category is 25,000 pounds. Usage calculations are performed in-house, and the facility prepared annual chemical usage spreadsheets for review during the inspection which are contained in Attachment 4.
The facility's usage calculations consider the weight percent of the elementa l or "parent" form of the metal (copper, manganese, and zinc), as shown on the ingredient labels of their various trace mineral mixes; however, those labels also show that the metals are actually present in compound forms (such as copper sulfate, manganous oxide, and zinc sulfate). When a metal is in a compound form, the entire weight of the metal compound should be applied towards calculating annua l usage. I utilized the facility's ca lcu lations to determine the corresponding amounts of metal compounds that were processed for each year. These calculations are shown in Appendix 5.
The table below shows a summary of meta l compound usage fo r each year, based on my calculations. It also indicates whether or not a Form A was filed. Amounts that exceed the processing threshold are in bold type.
Chemical
Copper co mpounds Manganese compounds
2011
pounds used
16,113 Not filed
28,356 Filed
2012
pounds used
12,933 Not filed
23,848 Filed
2013
pounds used
12,821 Not filed
24,042 Not filed
2014
pounds used
16,135 Filed
30,193 Filed
2015
pounds used
16,802
Not filed
Type of use
Processed
30,440 Filed
Processed
Zinc compounds
33,183 Filed
26,000 Not filed
28,170 Not filed
38,294 Filed
38,229 Filed
Processed
3
Land O' Lakes Purina Feed LLC- Shreveport Inspection Date: 05/23/2017
OTHER CHEMICALS USED BY THE FACILITY
Selenium compounds were processed for each year covered by the inspection, but annual usage did not exceed the reporting threshold of 25,000 lbs.
Chemical
Selenium compounds
2011 pounds used
15
2012 pound s used
126
2013 pounds used
129
2014 pounds used
152
2015 pounds used
166
Type of use Processed
CERTIFICATION DATES OF FORMS
Forms for each calendar year are due by July 1st of the following year. An Envirofacts database query of the dates on which the facility filed its forms is contained in Appendix 6.
Year 2011 2012 2013 2014
2015
Chemical Manganese compounds, zinc compounds Manganese compounds none Copper compounds, manganese compounds, zinc compounds Manganese compounds, zinc compounds
Original postmark date June 27, 2012 June 29, 2013 Not applicable June 22, 2015
June 30, 2016
Comment On -t i m e On-time Not applicable On-time
On-time
FORM A CERTIFICATION STATEMENTS
For reporting years 2011, 2012, 2014, and 2015, the facility submitted Form A certification statements, rather than Form R reports. EPCRA 313 does not consider copper compounds, manganese compounds, or zinc compounds to be "persistent, bioaccumulative, and toxic"; therefore, a facility is able to submit a simplified Form A, instead of a Form R, provided that the following two criteria are met for a given year:
The fa cility manufactures/processes/otherwise uses less than 1,000,000 lbs. of that chemical.
The annual reportable amount (ARA) for that chemical is less than 500 lbs. The ARA is the combined total quantities released at the facility, treated at the facility, recovered at the facility as a re sult of recycling operations, combusted for the purpose of energy recovery at the facility, and amounts transferred from the facility to off-site locations for the purpose of recycling, energy recovery, treatment, and/or disposal. These quantities correspond to the sum of amounts reportable on the Form R, Part II column B of section 8, data elements 8.1 (quantity released), 8.2 (quantity used for energy recovery on-site), 8.3 (quantity used ~or
4
Land O' Lakes Purina Feed LLC- Shreveport Inspection Date: 05/23/2017
energy recovery off-site), 8.4 (quantity recycled onsite), 8.5 (quantity recycled off-site), 8.6 (quantity treated on-site), and 8.7 (quantity treated off-site).
By signing the Form A, the facility is certifying that the chemical meets those two criteria, and records supporting this must be retained for a period of three years from the date of submission. The facility did not have these records available at the time of the inspection; however, releases and other elements were discussed. The facility did follow up with information related to production amounts and waste management, which is contained in Appendix 7. The applicable data elements are discussed below. Note: while annual usage calculations for metal compounds consider the entire weight of the compound, the releases, transfers, and other waste management consider only the weight of the elemental metal.
Data Ele ment 8.1- Quantity Released: The facility provided information on total amounts of waste material transferred off-site for disposal, as well as product manufactured, for each year. Using this information, the inspector estimated the amounts of elemental metal transferred offsite for disposal for each year. These calculations assume that the percentages of reportable chemicals in each year's waste are equivalent to the percentages in each year's manufactured product. The calculations are contained in Appendix 8.
Year
2011 2012 2013 2014 2015
M etal
Copper Manganese
Zinc Copper Manganese
Zinc Copper Manganese
Zinc Copper Manganese
Zinc Copper Manganese
Zinc
Amount sent off-site for disposal (pounds)
1 4 5 2 6 6 5 16 19 16 50 63 7 20 25
5
Land O'Lakes Purina Feed LLC - Shreveport Inspection Date: 05/23/2017
Appendix 1 Business Card
Land O'Lakes Purina Feed LLC - Shreveport Inspection Date: 05/23/2017
Appendix 2 Facility Map
Land O'Lakes Purina Feed LLC - Shreveport Inspection Date: 05/23/2017
Appendix 3 Process Flow Diagram
Land O'Lakes Purina Feed LLC - Shreveport Inspection Date: 05/23/2017
Appendix 4 Facility's Chemical Usage Calculations
Land O'Lakes Purina Feed LLC - Shreveport Inspection Date: 05/23/2017
Appendix 5 Inspector's Chemical Usage Calculations
Based on parent metal = no reports. Based on metal compound = Mn compounds & Zn compounds exceed threshold.
RY Product Name
Chemical Category Name
Chemical Category Number
Conc. of parent metala
Lbs. of product used
Lbs. of Parent Metal Used
Total Lbs. of Parent
Metal Used
MW of Parent Metal
2011 Zinc sulfate
zinc compound (ZnSO4)
N982
35.50%
600
213
65.38
Zinc oxide
zinc compound (ZnO)
N982
72.00% 1,200
864
65.38
Dairy premix
zinc compound (ZnSO4)
N982
11.00% 10,300
1,133
65.38
Horse trace premix zinc compound (ZnO)
N982
12.80% 90,000 11,520
65.38
Trace minerals A
zinc compound (ZnO)
N982
12.95%
750
97 20,152
65.38
Trace minerals G
zinc compound (ZnSO4, Zn?, ZnO)
N982
9.60% 6,300
605
65.38
Sheep trace minerals zinc compound (ZnO, ZnSO4)
N982
20.00% 5,300
1,060
65.38
Beef mineral premix zinc compound (ZnSO4)
N982
17.50% 26,000
4,550
65.38
Swine mineral premix zinc compound (ZnSO4)
N982
14.71%
750
110
65.38
Copper sulfate
copper compound (CuSO4)
N100
25.20% 4,650
1,172
63.55
Dairy premix
copper compound (CuSO4)
N100
2.50% 10,300
258
63.55
Horse trace premix copper compound (CuSO4)
N100
3.20% 90,000
2,880
63.55
Trace minerals A
copper compound (CuSO4)
N100
1.25%
750
9 5,890
63.55
Trace minerals G
copper compound (basic CuCl, CuSO4, Cu?, CuO) N100
3.20% 6,300
202
63.55
Beef mineral premix copper compound (basic CuCl)
N100
5.20% 26,000
1,352
63.55
Swine mineral premix copper compound (CuSO4, basic CuCl)
N100
2.36%
750
18
63.55
Manganous oxide manganese compound (MnO)
N450
60.00% 1,350
810
54.94
Dairy premix
manganese compound (MnSO4)
N450
8.20% 10,300
845
54.94
Horse trace premix manganese compound (MnO)
N450
12.80% 90,000 11,520
54.94
Trace minerals A Trace minerals G
manganese compound (MnO) manganese compound (MnSO4, Mn?, MnO)
N450 N450
17.50% 9.60%
750 6,300
131 17,390
605
54.94 54.94
Sheep trace minerals manganese compound (MnO, MnSO4)
N450
16.00% 5,300
848
54.94
Beef mineral premix manganese compound (MnSO4)
N450
10.00% 26,000
2,600
54.94
Swine mineral premix manganese compound (MnO, MnSO4)
N450
4.12%
750
31
54.94
Selenium
selenuim compound (Na2SeO3)
N725
0.06% 11,600
7
7
78.96
a - As shown on ingredient label. b - When more than one compound is listed for a product, the first compound listed is used. To determine amount of metal compound used, divide the molecular weight (MW) of the metal compound by the MW of the metal, then multiply by "Lbs. of Parent Metal Used".
MW of Metal Comp. in Column Cb
Lbs. of Metal Comp. Used
Total Lbs. of Metal
Comp. Used
161.47
526
81.38
1,075
161.47
2,798
81.38 14,339
81.38
121 33,183
161.47
1,494
81.38
1,319
161.47 11,237
161.47
272
159.61
2,943
159.61
647
159.61
7,234
159.61
24 16,113
213.56
678
213.56
4,544
159.61
44
70.94
1,046
151.00
2,321
70.94 14,875
70.94 151.00
169 1,662
28,356
70.94
1,095
151.00
7,146
70.94
40
172.95
15 15
Based on parent metal = no reports. Based on metal compound = Zn compounds exceed threshold.
RY Product Name
Chemical Category Name
Chemical Category Number
Conc. of parent metala
Lbs. of product used
Lbs. of Parent Metal Used
Total Lbs. of Parent
Metal Used
MW of Parent Metal
2012 Zinc sulfate
zinc compound (ZnSO4)
N982
35.50%
400
142
65.38
Zinc oxide
zinc compound (ZnO)
N982
72.00%
700
504
65.38
Dairy premix
zinc compound (ZnSO4)
N982
11.00% 7,150
787
65.38
Horse trace premix zinc compound (ZnO)
N982
12.80% 80,000 10,240
65.38
Trace minerals A
zinc compound (ZnO)
N982
12.95% 9,300
1,204 16,935
65.38
Trace minerals G
zinc compound (ZnSO4, Zn?, ZnO)
N982
9.60% 3,750
360
65.38
Sheep trace minerals zinc compound (ZnO, ZnSO4)
N982
20.00% 4,850
970
65.38
Beef mineral premix zinc compound (ZnSO4)
N982
17.50% 14,750
2,581
65.38
Swine mineral premix zinc compound (ZnSO4)
N982
14.71% 1,000
147
65.38
Copper sulfate
copper compound (CuSO4)
N100
25.20% 4,300
1,084
63.55
Dairy premix
copper compound (CuSO4)
N100
2.50% 7,150
179
63.55
Horse trace premix copper compound (CuSO4)
N100
3.20% 80,000
2,560
63.55
Trace minerals A
copper compound (CuSO4)
N100
1.25% 9,300
116 4,849
63.55
Trace minerals G
copper compound (basic CuCl, CuSO4, Cu?, CuO) N100
3.20% 3,750
120
63.55
Beef mineral premix copper compound (basic CuCl)
N100
5.20% 14,750
767
63.55
Swine mineral premix copper compound (CuSO4, basic CuCl)
N100
2.36% 1,000
24
63.55
Manganous oxide manganese compound (MnO)
N450
60.00% 1,050
630
54.94
Dairy premix
manganese compound (MnSO4)
N450
8.20% 7,150
586
54.94
Horse trace premix manganese compound (MnO)
N450
12.80% 80,000 10,240
54.94
Trace minerals A Trace minerals G
manganese compound (MnO) manganese compound (MnSO4, Mn?, MnO)
N450 N450
17.50% 9.60%
9,300 3,750
1,628 360
15,736
54.94 54.94
Sheep trace minerals manganese compound (MnO, MnSO4)
N450
16.00% 4,850
776
54.94
Beef mineral premix manganese compound (MnSO4)
N450
10.00% 14,750
1,475
54.94
Swine mineral premix manganese compound (MnO, MnSO4)
N450
4.12% 1,000
41
54.94
Selenium
selenuim compound (Na2SeO3)
N725
0.06% 96,000
58
58
78.96
a - As shown on ingredient label. b - When more than one compound is listed for a product, the first compound listed is used. To determine amount of metal compound used, divide the molecular weight (MW) of the metal compound by the MW of the metal, then multiply by "Lbs. of Parent Metal Used".
MW of Metal Comp. in Column Cb
Lbs. of Metal Comp. Used
Total Lbs. of Metal
Comp. Used
161.47
351
81.38
627
161.47
1,942
81.38 12,746
81.38
1,499 26,000
161.47
889
81.38
1,207
161.47
6,375
161.47
363
159.61
2,722
159.61
449
159.61
6,430
159.61
292 12,933
213.56
403
213.56
2,578
159.61
59
70.94
814
151.00
1,611
70.94 13,223
70.94 151.00
2,102 989
23,848
70.94
1,002
151.00
4,054
70.94
53
172.95
126 126
Based on parent metal = no reports. Based on metal compound = Mn compounds exceed threshold.
RY Product Name
Chemical Category Name
Chemical Category Number
Conc. of parent metala
Lbs. of product used
Lbs. of Parent Metal Used
Total Lbs. of Parent
Metal Used
MW of Parent Metal
2013 Zinc sulfate
zinc compound (ZnSO4)
N982
35.50% 1,100
391
65.38
Zinc oxide
zinc compound (ZnO)
N982
72.00% 1,750
1,260
65.38
Dairy premix
zinc compound (ZnSO4)
N982
11.00% 8,500
935
65.38
Horse trace premix zinc compound (ZnO)
N982
12.80% 72,000
9,216
65.38
Trace minerals A
zinc compound (ZnO)
N982
12.95% 9,500
1,230 17,674
65.38
Trace minerals G
zinc compound (ZnSO4, Zn?, ZnO)
N982
9.60% 6,300
605
65.38
Sheep trace minerals zinc compound (ZnO, ZnSO4)
N982
20.00% 4,650
930
65.38
Beef mineral premix zinc compound (ZnSO4)
N982
17.50% 17,000
2,975
65.38
Swine mineral premix zinc compound (ZnSO4)
N982
14.71%
900
132
65.38
Copper sulfate
copper compound (CuSO4)
N100
25.20% 3,950
995
63.55
Dairy premix
copper compound (CuSO4)
N100
2.50% 8,500
213
63.55
Horse trace premix copper compound (CuSO4)
N100
3.20% 72,000
2,304
63.55
Trace minerals A
copper compound (CuSO4)
N100
1.25% 9,500
119 4,737
63.55
Trace minerals G
copper compound (basic CuCl, CuSO4, Cu?, CuO) N100
3.20% 6,300
202
63.55
Beef mineral premix copper compound (basic CuCl)
N100
5.20% 17,000
884
63.55
Swine mineral premix copper compound (CuSO4, basic CuCl)
N100
2.36%
900
21
63.55
Manganous oxide manganese compound (MnO)
N450
60.00%
950
570
54.94
Dairy premix
manganese compound (MnSO4)
N450
8.20% 8,500
697
54.94
Horse trace premix manganese compound (MnO)
N450
12.80% 72,000
9,216
54.94
Trace minerals A Trace minerals G
manganese compound (MnO) manganese compound (MnSO4, Mn?, MnO)
N450 N450
17.50% 9.60%
9,500 6,300
1,663 605
15,231
54.94 54.94
Sheep trace minerals manganese compound (MnO, MnSO4)
N450
16.00% 4,650
744
54.94
Beef mineral premix manganese compound (MnSO4)
N450
10.00% 17,000
1,700
54.94
Swine mineral premix manganese compound (MnO, MnSO4)
N450
4.12%
900
37
54.94
Selenium
selenuim compound (Na2SeO3)
N725
0.06% 98,000
59
59
78.96
a - As shown on ingredient label. b - When more than one compound is listed for a product, the first compound listed is used. To determine amount of metal compound used, divide the molecular weight (MW) of the metal compound by the MW of the metal, then multiply by "Lbs. of Parent Metal Used".
MW of Metal Comp. in Column Cb
Lbs. of Metal Comp. Used
Total Lbs. of Metal
Comp. Used
161.47
964
81.38
1,568
161.47
2,309
81.38 11,471
81.38
1,531 28,170
161.47
1,494
81.38
1,158
161.47
7,347
161.47
327
159.61
2,500
159.61
534
159.61
5,787
159.61
298 12,821
213.56
678
213.56
2,971
159.61
53
70.94
736
151.00
1,916
70.94 11,900
70.94 151.00
2,147 1,662
24,042
70.94
961
151.00
4,673
70.94
48
172.95
129 129
Based on parent metal = no reports. Based on metal compound = Mn compounds & Zn compounds exceed threshold.
RY Product Name
Chemical Category Name
Chemical Category Number
Conc. of parent metala
Lbs. of product used
Lbs. of Parent Metal Used
Total Lbs. of Parent
Metal Used
MW of Parent Metal
2014 Zinc sulfate
zinc compound (ZnSO4)
N982
35.50% 2,050
728
65.38
Zinc oxide
zinc compound (ZnO)
N982
72.00% 4,100
2,952
65.38
Dairy premix
zinc compound (ZnSO4)
N982
11.00% 21,000
2,310
65.38
Horse trace premix zinc compound (ZnO)
N982
12.80% 74,000
9,472
65.38
Trace minerals A
zinc compound (ZnO)
N982
12.95% 13,750
1,781 23,047
65.38
Trace minerals G
zinc compound (ZnSO4, Zn?, ZnO)
N982
9.60% 3,250
312
65.38
Sheep trace minerals zinc compound (ZnO, ZnSO4)
N982
20.00% 5,000
1,000
65.38
Beef mineral premix zinc compound (ZnSO4)
N982
17.50% 25,000
4,375
65.38
Swine mineral premix zinc compound (ZnSO4)
N982
14.71%
800
118
65.38
Copper sulfate
copper compound (CuSO4)
N100
25.20% 5,800
1,462
63.55
Dairy premix
copper compound (CuSO4)
N100
2.50% 21,000
525
63.55
Horse trace premix copper compound (CuSO4)
N100
3.20% 74,000
2,368
63.55
Trace minerals A
copper compound (CuSO4)
N100
1.25% 13,750
172 5,949
63.55
Trace minerals G
copper compound (basic CuCl, CuSO4, Cu?, CuO) N100
3.20% 3,250
104
63.55
Beef mineral premix copper compound (basic CuCl)
N100
5.20% 25,000
1,300
63.55
Swine mineral premix copper compound (CuSO4, basic CuCl)
N100
2.36%
800
19
63.55
Manganous oxide manganese compound (MnO)
N450
60.00% 1,700
1,020
54.94
Dairy premix
manganese compound (MnSO4)
N450
8.20% 21,000
1,722
54.94
Horse trace premix manganese compound (MnO)
N450
12.80% 74,000
9,472
54.94
Trace minerals A Trace minerals G
manganese compound (MnO) manganese compound (MnSO4, Mn?, MnO)
N450 N450
17.50% 9.60%
13,750 3,250
2,406 312
18,265
54.94 54.94
Sheep trace minerals manganese compound (MnO, MnSO4)
N450
16.00% 5,000
800
54.94
Beef mineral premix manganese compound (MnSO4)
N450
10.00% 25,000
2,500
54.94
Swine mineral premix manganese compound (MnO, MnSO4)
N450
4.12%
800
33
54.94
Selenium
selenuim compound (Na2SeO3)
N725
0.06% 116,000
70
70
78.96
a - As shown on ingredient label. b - When more than one compound is listed for a product, the first compound listed is used. To determine amount of metal compound used, divide the molecular weight (MW) of the metal compound by the MW of the metal, then multiply by "Lbs. of Parent Metal Used".
MW of Metal Comp. in Column Cb
Lbs. of Metal Comp. Used
Total Lbs. of Metal
Comp. Used
161.47
1,797
81.38
3,674
161.47
5,705
81.38 11,790
81.38
2,216 38,294
161.47
771
81.38
1,245
161.47 10,805
161.47
291
159.61
3,671
159.61
1,319
159.61
5,948
159.61
432 16,135
213.56
350
213.56
4,369
159.61
47
70.94
1,317
151.00
4,733
70.94 12,231
70.94 151.00
3,107 858
30,193
70.94
1,033
151.00
6,871
70.94
43
172.95
152 152
Based on parent metal = no reports. Based on metal compound = Mn compounds & Zn compounds exceed threshold.
RY Product Name
Chemical Category Name
Chemical Category Number
Conc. of parent metala
Lbs. of product used
Lbs. of Parent Metal Used
Total Lbs. of Parent
Metal Used
MW of Parent Metal
2015 Zinc sulfate
zinc compound (ZnSO4)
N982
35.50% 2,050
728
65.38
Zinc oxide
zinc compound (ZnO)
N982
72.00% 5,100
3,672
65.38
Dairy premix
zinc compound (ZnSO4)
N982
11.00% 15,500
1,705
65.38
Horse trace premix zinc compound (ZnO)
N982
12.80% 78,000
9,984
65.38
Trace minerals A
zinc compound (ZnO)
N982
12.95% 10,000
1,295 23,440
65.38
Trace minerals G
zinc compound (ZnSO4, Zn?, ZnO)
N982
9.60% 4,450
427
65.38
Sheep trace minerals zinc compound (ZnO, ZnSO4)
N982
20.00% 5,500
1,100
65.38
Beef mineral premix zinc compound (ZnSO4)
N982
17.50% 25,000
4,375
65.38
Swine mineral premix zinc compound (ZnSO4)
N982
14.71% 1,050
154
65.38
Copper sulfate
copper compound (CuSO4)
N100
25.20% 6,850
1,726
63.55
Dairy premix
copper compound (CuSO4)
N100
2.50% 15,500
388
63.55
Horse trace premix copper compound (CuSO4)
N100
3.20% 78,000
2,496
63.55
Trace minerals A
copper compound (CuSO4)
N100
1.25% 10,000
125 6,202
63.55
Trace minerals G
copper compound (basic CuCl, CuSO4, Cu?, CuO) N100
3.20% 4,450
142
63.55
Beef mineral premix copper compound (basic CuCl)
N100
5.20% 25,000
1,300
63.55
Swine mineral premix copper compound (CuSO4, basic CuCl)
N100
2.36% 1,050
25
63.55
Manganous oxide manganese compound (MnO)
N450
60.00% 3,300
1,980
54.94
Dairy premix
manganese compound (MnSO4)
N450
8.20% 15,500
1,271
54.94
Horse trace premix manganese compound (MnO)
N450
12.80% 78,000
9,984
54.94
Trace minerals A Trace minerals G
manganese compound (MnO) manganese compound (MnSO4, Mn?, MnO)
N450 N450
17.50% 9.60%
10,000 4,450
1,750 427
18,835
54.94 54.94
Sheep trace minerals manganese compound (MnO, MnSO4)
N450
16.00% 5,500
880
54.94
Beef mineral premix manganese compound (MnSO4)
N450
10.00% 25,000
2,500
54.94
Swine mineral premix manganese compound (MnO, MnSO4)
N450
4.12% 1,050
43
54.94
Selenium
selenuim compound (Na2SeO3)
N725
0.06% 126,000
76
76
78.96
a - As shown on ingredient label. b - When more than one compound is listed for a product, the first compound listed is used. To determine amount of metal compound used, divide the molecular weight (MW) of the metal compound by the MW of the metal, then multiply by "Lbs. of Parent Metal Used".
MW of Metal Comp. in Column Cb
Lbs. of Metal Comp. Used
Total Lbs. of Metal
Comp. Used
161.47
1,797
81.38
4,571
161.47
4,211
81.38 12,427
81.38
1,612 38,229
161.47
1,055
81.38
1,369
161.47 10,805
161.47
381
159.61
4,336
159.61
973
159.61
6,269
159.61
314 16,802
213.56
479
213.56
4,369
159.61
62
70.94
2,557
151.00
3,493
70.94 12,892
70.94 151.00
2,260 1,174
30,440
70.94
1,136
151.00
6,871
70.94
56
172.95
166 166
Land O'Lakes Purina Feed LLC - Shreveport Inspection Date: 05/23/2017
Appendix 6 Certification Dates of Forms
Page 1 of 1
TRI EZ Query Results
TRI Facility Id Equal to 71106PRNML223WE Reporting Year Greater than/Equal to 2011 Results are based on data extracted on 01-MAR-17
Page No. 1
Generated SQL
Select distinct V_TRI_SUBMISSIONS_EZ.TRI_FACILITY_ID, V_TRI_SUBMISSIONS_EZ.FACILITY_NAME, V_TRI_SUBMISSIONS_EZ.REPORTING_YEAR, V_TRI_SUBMISSIONS_EZ.CHEM_NAME,
V_TRI_SUBMISSIONS_EZ.FORM_TYPE_IND, to_char(V_TRI_SUBMISSIONS_EZ.ORIG_POSTMARK, 'YYYY-MM-DD') from V_TRI_SUBMISSIONS_EZ where (V_TRI_SUBMISSIONS_EZ.TRI_FACILITY_ID = '71106PRNML223WE') and
(V_TRI_SUBMISSIONS_EZ.REPORTING_YEAR >= '2011') order by V_TRI_SUBMISSIONS_EZ.REPORTING_YEAR asc , V_TRI_SUBMISSIONS_EZ.CHEM_NAME asc
TRI Facility Id
Facility Name
71106PRNML223WE LAND O'LAKES PURINA FEED LLC - SHREVEPORT 71106PRNML223WE LAND O'LAKES PURINA FEED LLC - SHREVEPORT 71106PRNML223WE LAND O'LAKES PURINA FEED LLC - SHREVEPORT 71106PRNML223WE LAND O'LAKES PURINA FEED LLC - SHREVEPORT 71106PRNML223WE LAND O'LAKES PURINA FEED LLC - SHREVEPORT 71106PRNML223WE LAND O'LAKES PURINA FEED LLC - SHREVEPORT 71106PRNML223WE LAND O'LAKES PURINA FEED LLC - SHREVEPORT 71106PRNML223WE LAND O'LAKES PURINA FEED LLC - SHREVEPORT
Reporting Year 2011 2011 2012 2014 2014 2014 2015 2015
Chemical Name
MANGANESE COMPOUNDS
Form Type Indicator
S
ZINC COMPOUNDS S
MANGANESE COMPOUNDS S
COPPER COMPOUNDS S
MANGANESE COMPOUNDS S
ZINC COMPOUNDS S
MANGANESE COMPOUNDS S
ZINC COMPOUNDS S
Orig Postmark JUN-27-2012 JUN-27-2012 JUN-29-2013 JUN-22-2015 JUN-22-2015 JUN-22-2015 JUN-30-2016 JUN-30-2016
Total number of records returned from your query: 8 Number of Records shown on this page: 8 ***
Output to CSV File
***The result set above presents a list of unique data in the output. If you would like to run the query again and obtain a result set that lists all data, please click here . This query can potentially take a longer time to complete, than your previous query. This is due to the larger quantity of data retrieved.
EPA Home | Contact Us Last updated on Monday, May 22nd, 2017
https://ofmint.rtpnc.epa.gov/enviro/ez_build_sql2.get_table
5/22/2017
Land O'Lakes Purina Feed LLC - Shreveport Inspection Date: 05/23/2017
Appendix 7 Facility Emails
Riley, David
From: Sent: To: Cc: Subject:
Kennedy, Todd <TTKennedy@landolakes.com> Tuesday, May 23, 2017 2:34 PM Riley, David Gueringer, Billy; Hines, Jennifer Additional Information Request - Purina, Shreveport
David,
I have gathered the information on materials disposed of at an off-site facility as requested. Amounts are listed as follows:
2011 - 28 Tons, or 0.02% 2012 - 36 Tons, or 0.038% 2013 - 103 Tons, or 0.1% 2014 - 283 Tons, or 0.27% 2015 - 124 Tons, or 0.10%
Total manufactured volume was 117,447 tons Total manufactured volume was 93,968 tons Total manufactured volume was 96,009 tons Total manufactured volume was 104,343 tons Total manufactured volume was 116,412 tons
In regard to dust control and how product is handled from this process, all collected product is immediately reintroduced to the process flow. We operate both bag house filters and cyclones for dust control at the facility. None of the product captured from these processes is sent to a storage bin for later use or disposal. It is all added back to the same production run it is collected from.
Please let me know if you have further questions.
Thank You,
Todd Kennedy l Purina Animal Nutrition, LLC Plant Manager 223 W. 63rd Street, Shreveport, LA 71106 Direct: 318-671-6362 l Cell: 601-504-7519 Office: 318-861-3506
_________________________________________
This message may contain confidential material from Land O'Lakes, Inc. (or its subsidiary) for the sole use of the intended recipient(s) and may not be reviewed, disclosed, copied, distributed or used by anyone other than the intended recipient(s). If you are not the intended recipient, please contact the sender by reply email and delete all copies of this message.
1
Riley, David
From: Sent: To: Subject:
Kennedy, Todd <TTKennedy@landolakes.com> Tuesday, June 27, 2017 9:12 AM Riley, David RE: EPCRA 313 inspection - additional questions on your process
The product from all dust collection systems is returned to the process system in which it was captured.
Todd Kennedy l Purina Animal Nutrition, LLC Plant Manager 223 W. 63rd Street, Shreveport, LA 71106 Direct: 318-671-6362 l Cell: 601-504-7519 Office: 318-861-3506
_________________________________________
From: Riley, David [mailto:riley.david@epa.gov] Sent: Tuesday, June 27, 2017 8:35 AM To: Kennedy, Todd <TTKennedy@landolakes.com> Subject: RE: EPCRA 313 inspection - additional questions on your process
Thank you very much! And regarding the cyclone/baghouse question: the cyclone dust is returned to pelleting. Is material from the baghouses also returned to various processes, or is this what is sent off-site for disposal?
David Riley EPCRA 313 Enforcement Officer US EPA Region 6 (EN-H3) 1445 Ross Avenue, Suite 1200 Dallas, TX 75202-2733
Phone: (214) 665-7298 Fax: (214) 665-6655 e-mail: riley.david@epa.gov
From: Kennedy, Todd [mailto:TTKennedy@landolakes.com] Sent: Tuesday, June 27, 2017 8:31 AM To: Riley, David <riley.david@epa.gov> Subject: RE: EPCRA 313 inspection - additional questions on your process
David,
1. We do produce both pelleted and meal animal foods. These are the two main types.
1
2. We have three cyclones on our pellet cooling systems. These are the only cyclones in the plant so they are only used during the pelleting process. We have multiple baghouses throughout the plant that are used in processes other than pelleting.
3. Your statement is basically correct. I am not sure of the date when the two divisions were split. It was in the late 70's, early 80's time frame to the best of my knowledge. Our company operated under Purina Mills until 2001, at which time it became Land O'Lakes Purina Mills, LLC. We are currently operating as Purina Animal Nutrition, LLC.
Hope this gives you what you need. Please let me know if you need further information.
Thanks
Todd Kennedy l Purina Animal Nutrition, LLC Plant Manager 223 W. 63rd Street, Shreveport, LA 71106 Direct: 318-671-6362 l Cell: 601-504-7519 Office: 318-861-3506
_________________________________________
From: Riley, David [mailto:riley.david@epa.gov] Sent: Tuesday, June 27, 2017 8:08 AM To: Kennedy, Todd <TTKennedy@landolakes.com> Subject: EPCRA 313 inspection - additional questions on your process
Good morning Todd -
I am currently finishing up a draft of the inspection report, and I have a few questions in order to verify that my notes are correct:
1. Does your facility produce both pellets and meal? (Are these the two main types of feed, or are there others?)
2. Is the cyclone/baghouse dust collection system only used during the pelletization process?
3. Regarding the facility history... I wrote down that it was built in 1953 by Ralston Purina for the manufacturing of livestock feed. In the late 1970s, the company's manufacturing was split into pet food (Ralston) and livestock feed (Purina Mills), with your facility continuing to operate under the Purina Mills name. Is that worded properly?
Thank you,
David Riley EPCRA 313 Enforcement Officer US EPA Region 6 (EN-H3) 1445 Ross Avenue, Suite 1200 Dallas, TX 75202-2733
2
Phone: (214) 665-7298 Fax: (214) 665-6655 e-mail: riley.david@epa.gov
This message may contain confidential material from Land O'Lakes, Inc. (or its subsidiary) for the sole use of the intended recipient(s) and may not be reviewed, disclosed, copied, distributed or used by anyone other than the intended recipient(s). If you are not the intended recipient, please contact the sender by reply email and delete all copies of this message. This message may contain confidential material from Land O'Lakes, Inc. (or its subsidiary) for the sole use of the intended recipient(s) and may not be reviewed, disclosed, copied, distributed or used by anyone other than the intended recipient(s). If you are not the intended recipient, please contact the sender by reply email and delete all copies of this message.
3
Land O'Lakes Purina Feed LLC - Shreveport Inspection Date: 05/23/2017
Appendix 8 Inspector's Release Calculations
Total manufactured amount of RY product, in tons
2011
117,447
Total manufactured amount of product, in lbs.
234,894,000
Chemical Category Name
zinc compounds copper compounds manganese compounds selenuim compounds
% of parent Total lbs. of metal in total
parent manufactured metal used amount
Waste material, in tons
20,152 5,890 17,390
7
0.0085793% 0.0025075% 28 0.0074031% 0.0000030%
Wate material, in lbs.
56,000
Amount of parent metal in waste material, in lbs.
5 1 4 0
Total manufactured amount of RY product, in tons
2012
93,968
Total manufactured amount of product, in lbs.
187,936,000
Chemical Category Name
zinc compounds copper compounds manganese compounds selenuim compounds
% of parent Total lbs. of metal in total
parent manufactured metal used amount
Waste material, in tons
16,935 4,849 15,736
58
0.0090112% 0.0025802% 36 0.0083731% 0.0000306%
Wate material, in lbs.
72,000
Amount of parent metal in waste material, in lbs.
6 2 6 0
Total manufactured amount of RY product, in tons
2013
96,009
Total manufactured amount of product, in lbs.
192,018,000
Chemical Category Name
zinc compounds copper compounds manganese compounds selenuim compounds
% of parent Total lbs. of metal in total
parent manufactured metal used amount
Waste material, in tons
17,674 4,737 15,231
59
0.0092043% 0.0024672% 103 0.0079323% 0.0000306%
Wate material, in lbs.
206,000
Amount of parent metal in waste material, in lbs.
19 5
16 0
Total manufactured amount of RY product, in tons
2014
104,343
Total manufactured amount of product, in lbs.
208,686,000
Chemical Category Name
zinc compounds copper compounds manganese compounds selenuim compounds
% of parent Total lbs. of metal in total
parent manufactured metal used amount
Waste material, in tons
23,047 5,949 18,265
70
0.0110439% 0.0028509% 283 0.0087525% 0.0000334%
Wate material, in lbs.
566,000
Amount of parent metal in waste material, in lbs.
63 16 50
0
Total manufactured amount of RY product, in tons
2015
116,412
Total manufactured amount of product, in lbs.
232,824,000
Chemical Category Name
zinc compounds copper compounds manganese compounds selenuim compounds
% of parent Total lbs. of metal in total
parent manufactured metal used amount
Waste material, in tons
23,440 6,202 18,835
76
0.0100679% 0.0026638% 124 0.0080900% 0.0000325%
Wate material, in lbs.
248,000
Amount of parent metal in waste material, in lbs.
25 7
20 0
"Total pounds of parent metal used" is taken from Appendix 5. Amounts of manufactured product and waste material are taken from Appendix 7.
Land O'Lakes Purina Feed LLC - Shreveport Inspection Date: 05/23/2017
Appendix 9 Recycling Excerpts from EPA Guidance
INTERPRETATIONS OF WASTE MANAGEMENT ACTIVITIES: RECYCLING, COMBUSTION FOR ENERGY RECOVERY, TREATMENT FOR DESTRUCTION, WASTE STABILIZATION AND RELEASE
Revised August, 1999 U.S. Environmental Protection Agency Office of Pollution Prevention and Toxics
401 M St., SW Washington, D.C. 20460
wastes. To ensure that there is some consistency between reporting under EPCRA and other environmental statutes, EPA believes that toxic chemicals that are constituents of or are hazardous wastes under RCRA should be considered toxic chemicals that are managed as waste, since by definition RCRA hazardous wastes are intended to be discarded. Therefore, practices affecting a toxic chemical identified as a RCRA hazardous waste, or that is a constituent of a RCRA hazardous waste would be considered to be waste management. A. Recycling
EPA interprets for the purposes of EPCRA section 313 "recycling" to be the following:
"Recycling" is (1) the recovery for reuse of a toxic chemical from a gaseous, aerosol, aqueous, liquid, or solid stream; or (2) the reuse, or the recovery for reuse of a toxic chemical that is a RCRA hazardous waste or is a constituent of a RCRA hazardous waste as defined in 40 CFR 261. "Recovery" is the act of extracting or removing the toxic chemical from a waste stream and includes: (1) the reclamation of the toxic chemical from a stream that entered a waste treatment or pollution control device or process where destruction of the stream or destruction or removal of certain constituents of the stream occurs (including air pollution control devices or processes, wastewater treatment or control devices or processes, Federal or State permitted treatment or control devices or processes, and other types of treatment or control devices or processes); and (2) the reclamation for reuse
10
of an "otherwise used" toxic chemical that is spent or contaminated and that must be recovered for further use in either the original or any other operations. EPA considers the direct recirculation of a toxic chemical within a process or between processes without any reclamation to be "reuse" of the toxic chemical rather than "recycling." The direct use, direct further use, or direct reuse of the toxic chemical is not "recycling" provided that there is no reclamation of the chemical prior to that continued use or reuse. EPA believes its approach most accurately describes practices that are not integral to production and practices affecting toxic chemicals that are amenable to source reduction and other forms of management. A practice that is not integral to production may be classified as a management activity, including recycling. EPA's interpretation of reportable "recycling" is therefore based on identifying practices involving the toxic chemical that are not integral to production. Recovery of a toxic chemical for reuse. EPA's interpretation of "recycling" includes the recovery of a toxic chemical from a chemical stream and the reuse of that chemical. The key to determining what is or is not integral to production is the definition of "recovery," which is the act of extracting or removing the toxic chemical from a chemical stream. EPA believes that recovery activities that are not integral to production include the following: (1) the recovery for reuse of a chemical from a stream that has entered a treatment or control device or process; and (2) the recovery for reuse of an "otherwise used" chemical that must be recovered prior to continued use. This
11
interpretation of "recovery" is intended to limit the scope of "recycling" based on the function of the toxic chemical, as well as the direction of the toxic chemical and chemical stream and the function of the device affecting the toxic chemical.
EPA believes that when the toxic chemical is recovered after entering a device or process that controls or treats the toxic chemical or chemical stream in order to make the toxic chemical or chemical stream more amenable for release or further management, the chemical should be considered as "recycled." EPA believes that such devices or processes are not integral to production because the direction of the stream is toward management or release and not toward the immediate processing of the toxic chemical. Therefore, regardless of the function or nature of the toxic chemical, the recovery and reuse of any toxic chemical after it has entered a treatment or control device or process is reportable "recycling" of that toxic chemical.
For example, a baghouse removes chemicals from an airstream prior to discharge. Some of the chemicals, including certain metal compounds, are recovered from the baghouse and returned to the process for "processing." The quantity of the chemicals recovered from the baghouse and returned to the process would not be considered integral to production and would be reportable as "recycled" because the baghouse prepares the stream containing the toxic chemical for release. For the purposes of the EPCRA section 313 reporting requirements, the treatment devices are NOT limited to those treatment devices that are Federally or State permitted. For EPCRA section 313 purposes, basing the criterion on whether a device is permitted is an unnecessary distinction. Not all devices that treat or control waste streams are
12