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