AQ_F_0800081_20170726_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Washiar, .i Regional Office
AIR QUALITY Valley Proteins-Lewiston Division
NC Facility ID 0800081
Inspection Report County/FIPS:Bertie/015
Date: 08/08/2017
Facility Data Permit Data
Valley Proteins-Lewiston Division Permit 03085/T31
3539 Governors Road Issued 6/17/2015
Lewiston Woodville,NC 27849 Expires 11/30/2018
Lat: 36d 8.4040m Long: 77d 13.4680m Classification Title V
SIC: 2048/Prepared Feeds Nec Permit Status Active
NAICS: 311119/Other Animal Food Manufacturing Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP/Title V
C.Anderson C.Anderson ✓ Robert Vogler MACT Part 63: Subpart 6J
General Manager General Manager Director of NSPS: Subpart Dc
[phone] [phone] Environmental Affairs
[phone]
Compliance Data
Comments: Based upon visual observation and records review,the facility
appeared to operate in compliance with the conditions of the permit at the Inspection Date 07/26/2017
time of the inspection. Inspector's Name Betsy Huddleston and
Rob Fisher
Inspector's Signature: Q� Operating Status Operating
//�/��✓ Compliance Code Compliance-inspection
4j Action Code FCE`
Date of Signature: 8/08/2017 (� On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP SO2 NOX VOC CO PMIO *HAP
2015 0.7900 1.26 4.67 17.04 3.46 0.7200 142.54
2014 1.92 0.1500 7.19 25.52 5.97 1.87 256.71
2013 0.9600 0,0200 3.73 18.87 3.12 0.8800 134.12
*Highest HAP Emitted(inpounds)
Five Year Violation History:None
Directions
Valley Proteins, Inc. operates a chicken rendering plant located on Highway 308 West, Lewiston Woodville,
Bertie County. Directions from Washington Regional Office are as follows:
• Follow Hwy 17 N to Windsor, and go through the first stoplight(funeral home on the right).
• At the second stoplight,turn left onto Highway 308 West.
• Stay on Highway 308 to Lewiston Woodville. The plant is located behind the Perdue chicken
processing plant on the left side of the road just north of the town.
• Turn left at the Perdue chicken plant and continue down the road past Perdue.
• There is a W.E. Partners facility at the entrance to the rendering plant, so drive past it and go
to the brick office building.

Safety Concerns
• There are trip and slip hazards. The floor is wet, and there are eye and floor level equipment.
• There are tractor trailers coming and going from the facility.
• Hearing protection,hard hat, safety glasses and safety shoes are required.
Permit History
The 5-yr permitting history for the rendering plant is provided as follows:
• T26 was issued on 7/25/2008 for replacement of the venturi scrubber(ID No. CD-IOC)with a
packed tower scrubber to reduce PM and SO2 emissions(ID No.CD-1 OF)from the boilers when
combusting oil and to reduce odor from the process equipment emissions. Perdue configured the two
remaining scrubbers(CD-1 OD and CD-l0E voluntary)for scrubbing emissions from roof vents and
the cookers(ES-10A,ES-1 OB,ES-IOD).
• T27 was issued on 12/11/2008 for a second temporary, back-up boiler(ID No. ES-24).
• T28 was issued on 5/05/2009 for permit renewal.
• T29 was issued on 10/17/2012 for change of ownership to Valley Proteins. Perdue Farms originally
held the Title V permit for this rendering plant.
• T30 was issued on 12/16/2013 for permit renewal.Valley Proteins requested removal of the PSD
avoidance condition limiting the amount of saleable fat that can be burned in boilers ES-8 and
ES-9. The facility provided revised emission factors for carbon monoxide(CO)that indicated
emissions from burning fat are far below the PSD threshold and an avoidance condition is
unnecessary. DAQ made several changes to the conditions with the renewal.
• A tax certification was issued to Valley Proteins on 8/27/2014 for the scrubbers,condensers and
the common cooling tower(which only serves the condensers), as well as their appurtenances.
Valley Proteins purchased the Perdue rendering plant in the fall of 2012,and this was their first
tax certification for the Lewiston facility. They reported that Perdue had previously applied for
tax certification for this equipment, but I could find no evidence in the DAQ file that Perdue had
submitted any previous tax certification applications.
• T31 was issued on 6/17/2015 for minor changes to the permit item list. The"poultry meal storage
silos"were changed to"meal storage silos," and the control devices for the silos were removed.
The meal storage silos(ID Nos. ES-II through ES-16) and the poultry meal loadout(ID No. ES-
19)were redesignated as insignificant activities based on revised emission factors. The"poultry
meal loadout"label changed to"meal loadout."
Process Description
1. Meat/feathers are received by trucks that dump at the receiving pad. There are three raw material
bays where the trucks dump(two are for meat and one is for feathers). There is also a grease hopper
that is now used for recycling tank bottoms(cleanout). Bone waste is metered into the meat mix.
The material is carried by conveyor and trash is removed.
2. Blood is pumped to holding tanks. It is then sent to two centrifuges,cooked and added to the feathers
before going to the dryer.
3. Trailers are rinsed and sanitized. Time cards are punched when the trucks come onto the property
and again when the trucks are dumped.
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4. The meat goes to the preneater or bypasses to the dual cooker. Mos .'the steam is usually provided
by the W.E. Partners boilers (Facility ID 0800107).
5. Meat is discharged from the preheater over a set of drainers to remove excess liquids (fat). The
drainer is hooded and ties into the press vent. The press and preheater vents are low pressure, so they
tie together and vent directly to the venturi scrubber and packed scrubber.
6. Liquid/fat goes to the evaporators. Waste heat from the cookers, feather dryer,hydrolyzer flash and
chamber is used to heat the evaporators. There is an emergency vent on the evaporators. The fat
moisture level is reduced by about half, and then the liquid concentrate is pumped to the meat
cookers.
7. Meat from the preheater is conveyed to either cooker. However, they have actually been regularly
using only the# 1 cooker,with the#2 cooker used for overflow raw material or testing. The#2
cooker does not require the use of the preheater.
8. The cookers discharge into a set of drainers where fat is drained off and pumped over a screening
system. The fat is then pumped to a centrifuge to remove remaining particles. The solids from the fat
are conveyed back to the presses and then cookers.
9. The fat is lastly pumped to centrifuge and holding tanks for shipment.
10. The meat from the cookers goes to four meat presses.All meat is pressed down to a low percentage of
fat. The fat from the press goes back to the screen and centrifuge.
it. Presses#1 and#3 feed to a bin and then to a grinder. Presses 42 and 44 feed to a bin and a second
grinder.
12. The meat(meal) goes through shakers and is conveyed to screens for sizing. It is then transferred to
silos for shipment. Oversized material from the screens is sent back to the grinders.
13. Feathers are processed separately from the meat product. They are transferred from the dump pad to
the hydrolyzer where they break down under pressure. They have a wet oatmeal appearance.
14. The feathers then go through a press where moisture is reduced by more than half. Blood is
centrifuged into a solid,and is metered into the feathers. The feathers are discharged into a flash
chamber,then to a blue-colored cooker(dryer)that is located between the two meat cookers.
Feathers are dried to very low moisture content. The hydrolyzer and feather cooker do not produce as
much condensate as the meat cookers.
15. The feather meal goes to a shaker screen and grinder that is located with the meat grinders. The
feather meal is then transferred to silos.
16. The cookers, hydrolyzer,flash chamber,and feather dryer all vent to the waste heat system before
venting to the venturi scrubber. The press and preheater emissions vent directly to the venturi
scrubber. From there all process emissions go to the packed scrubber. Process room air is pulled
under vacuum to a crossflow scrubber on the roof of the facility. The control device descriptions for
these emissions sources need to be edited in the next permit revision.
17. The meal loadout is located in a 3-sided building. Meal is sold to animal feed companies. Fat is sold
for re-blending in feed and as an ingredient in products such as cosmetics. Some nutrient additives
are applied during the rendering process according to client specification.
Permitted Sources/Inspection Observations
IV
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The following table contains a summary of all permitted and insignificant emission sources and
associated air pollution control devices. There is one cooling tower that may eventually need to be added
to the insignificant source list. Some observations from the inspection are noted in bold print.
Emission Emission Source Description Control Device Control Device Description
Source Ill No.a ID No.>
ES-8 Two natural gas/saleable animal CD-1 OF One packed bed scrubber(288 to
ES-9 fat/No. 6 fuel oil-fired boilers 575 gallon per minute normal
(GACT, (84 million Btu per hour maximum operating range)utilizing water,
Subpart heat input capacity, each) air, and filter media to reduce PM
JJJJJJ) The boilers alternate use since and S02 emissions in the boilers
70-80% of the steam is supplied and also used conditionally for
by W.E.Partners. ES-8 was additional control of
operating during the inspection. noncondensibles depending on
Boiler pressure was 127.2 psi, fuel fired in the boilers for the
and stack temperature was poultry processing equipment
337°F. The boiler was firing
natural gas.
ES-23 Two natural gas-fired temporary, NA NA No temporary boilers have
ES-24 back-up boilers(less than 90 been on-site since the last
(NSPS, million Btu per hour maximum inspection.
Subpart De) heat input capacity each
ES-10A.1 One poultry by-product cooker and CD-10E One venturi wet scrubber
one dual-use feather/poultry by- (voluntary for odor control state-
product cooker only requirement)
These sources are controlled 24/7 CD-1 OD One two-stage crossflow wet
by the venturi and packed bed scrubber(500 gallons per minute
scrubbers(there is no nominal liquid injection rate per
conditional use as described for stage)and a dry filter mist
CD-lOF). They do not vent to eliminator
the crossflow scrubber.
CD-10F One packed bed scrubber(288 to
The packed scrubber flow was 575 gallon per minute normal
400 gpm. operating range)utilizing water,
air,and filter media to reduce PM
and S02 emissions in the boilers
and also used conditionally for
additional control of
noncondensibles depending on
fuel fired in the boilers for the
poultry processing equipment
L One feather dryer and one CD-10E See above descriptions
hydrolyzer CD-lOD These sources are controlled
CD-10F 24/7 by the venturi and packed
bed scrubbers.They do not vent
to the crossflow scrubber.
ES-10B Poultry by-product presses and CD-10D See above descriptions
preheater CD-10F These sources do not vent to the
waste heat system, but vent
directly to the venturi and
packed bed scrubbers.
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Emission Emission Source Descriptioni Control Device " Control Device Description
Source ID No. : ID No,,
ES-1 OD Process room air collection CD-lOD See above descriptions
Room air is controlled only by CD-lOF The crossflow scrubber
the crossflow scrubber. flowmeters read 550 gpm and
575 gpm.
ES-10E Two liquid/fat evaporators CD-10E See above descriptions
One of the evaporators has not CD-lOD The evaporators vent to the
been in use for the last couple of CD-10F venturi and packed bed
ears. scrubbers.
Insignificant Sources
ID Number Equipment Description,
IES17 Poultry meal conveyance system
I-WCCS Wastewater collection and conveyance system
IES-11 —IES-16 Six(6)meal storage silos(ES-11 and ES-14 are 300 tons capacity and the
rest are 100 tons capacity)
IES-19 Meal loadout aLea(54 tons per hour capacity)
Rob Fisher and I performed records review and physical inspection of the rendering plant on 7/26/2017. The
inspection was performed using the current Title V permit(T31). Records were reviewed back to August
2016. The inspection was completed with assistance from Mr. Mike Anderson(plant manager).
The plant operation was intermittent during the inspection, and was processing primarily feathers. The
plant was down while we were on the roof inspecting the condensers and scrubbers. Process equipment
emissions exhaust through the venturi scrubber and packed bed scrubber. The packed scrubber is filled
with stainless media. The scrubber water flow was observed at 400 gpm. Mr.Anderson previously noted
that airflow to the packed scrubber is approximately 86,000 ACFM. Room air vents are connected to the
crossflow scrubber. Flows to the crossflow scrubber during the inspection were 550 and 575 gpm.
All of the facility control devices appeared to be in good condition. There were no holes or tears observed in
the ductwork or control devices.
The plant generally only operates on Saturdays and Sundays if there are overflow loads or backlogged
loads. Most of the meat and feathers are supplied by the Perdue processing facility next door, but they do
receive several loads a day from other facilities. The No.I meat cooker has been operating mostly
afternoon and at night. Feathers are processed round the clock with 3-4 down hours per day. Mr.
Anderson said they plan to keep to the current daily processing schedule through the winter to help
Perdue with some wastewater issues.
Regulatory Review
Two natural gas/saleable animal fats/No. 6 fuel oil-fired boilers (ID Nos. ES-8 and ES-9)
with associated packed tower scrubber (ID No. CD-10F) and two natural gas-fired
temporary, back-up boilers (ID Nos. ES-23 and ES-24)
Regulated Limits/Standards Applicable Regulation
Pollutant
Particulate matter 0.27 pounds per million Btu heat input(ES-8 and ES-9) 15A NCAC 2D .0503
0.25 pounds per million Btu heat input(ES-23)
0.23 pounds per million Btu heat input(ES-24)
Sulfur dioxide 2.3 pounds per million Btu heat input 15A NCAC 2D .0516
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Regulated! Limits/Standards Applicable Regulation
„ Pollutant r
Visible emissions 20 percent opacity 15A NCAC 2D .0521
TSP Less than 41 tons per year combined 15A NCAC 2Q .0317
PM10 Less than 28 tons per year combined (PSD Avoidance)
Sulfur dioxide Less than 215 tons per year combined
VOCs Less than 40 tons per year combined
Carbon monoxide Less than 106 tons per year combined(as aggregate of
Nitrogen oxides all fuel combustion)
Less than 107 tons per year combined
Hazardous air National Emission Standards for Hazardous Air 15A NCAC 2D .1111
pollutants Pollutants for Area Sources—Industrial,Commercial, (40 CFR 63, Subpart JJJJJJ)
and Institutional Boilers
W.E. Partners supplies 70-80% of the steam demand at the rendering plant. W.E.Partners is not capable
of making enough steam to supply 100% if Valley is in full production. Valley Proteins usually operates
one of the boilers(they alternate). On a continuous full operation day the steam demand averages about
75,000-80,000 lbs/hr.
Boiler ES-9 has been shut down since November 2016 for re-tubing.
2D.0503 "Particulates from Fuel Burning Indirect Heat Exchangers"
Permit Conditions 2.I.A.1. and 2.I.B.1.
The boilers have never been tested for particulate.No temporary boilers have been used since the date of
last inspection. There has been no curtailment since the last inspection. They may receive as little as 6-7
hours' notice of any curtailment.
ES-8 and ES-9 each have an emission limit of 0.27 lb/MMBtu, and the temporary boilers have limits of 0.25
lb/MMBtu and 0.23 Ib/MMBtu. Assuming worst case No. 6 fuel usage, boiler ES-8 and ES-9 uncontrolled
particulate emissions are estimated using an AP-42 factor:
88,400,000 Btu/hr(gallon/1 5 1,000 Btu)(24 lb/1000 gallons)= 14.05 Ibs/hr emitted
14.05 Ibs/hr(hr/88.4 MMBtu)=0.16 lb/MMBtu
The temporary boilers would operate on natural gas. The AP-42 emission factor for particulate from natural
gas combustion is 0.007 lb/MvlBtu.
There are no monitoring/recordkeeping/reporting(MRR)conditions for 2D.0503. Valley Proteins is in
compliance with 2D.0503.
2D.0516 "Sulfur Dioxide Emissions from Combustion Sources"
Permit Conditions 2.I.A.2. and 2.I.B.2.
The regulation applies to the No. 6 fuel oil and natural gas combustion in the boilers. No animal fats have
ever been combusted at the facility. No monitoring is required for natural combustion. Permit Specific
Condition 2.1.A.2.d. states that the sulfur content in the fuel oil must not exceed 2.1% by weight. Permit
condition 2.1.A.2.e. and g. require Valley Proteins to maintain sulfur certifications per shipment of fuel oil,
and to submit semi-annual fuel oil sulfur certification summary reports to DAQ. No fuel oil shipments have
been received since 2/20/2015. The certification reported 0.47% sulfur content.Valley Proteins has submitted
complete semi-annual reports on time. Valley Proteins is in compliance with 2D.0516.
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2D.0521 "Control of Visible Ertdssions"
Permit Conditions 2.I.A.3. and 2.1.B.3.
Visible emissions from all of the boilers must not exceed 20 percent opacity when averaged over a six-
minute period. Six-minute averaging periods may exceed 20 percent not more than once in any hour and
not more than four times in any 24-hour period. We did not observe any opacity from boiler ES-8 during
the inspection(just heat waves).
There are no monitoring/recordkeeping/reporting requirements for the temporary boilers. Permit
Condition 2.1.A.3.d. requires weekly visible emissions observation on ES-8 and ES-9 when combusting
No. 6 fuel oil. In the last year Valley Proteins has recorded weekly VE observations on the boilers for
both fuel oil and natural gas combustion. Since August 2016 fuel oil has been combusted on 1/07/2017,
2/18/2017 and 7/13/2017 (all on ES-8). There were visible emissions observation records for those dates,
and all indicated 0% opacity.
I believe the VE observation requirement for the boilers on No. 6 oil can be removed in the next permit
modification. The boiler emissions are vented to the packed scrubber,which creates a very visibly wet
plume. The facility usually burns the oil only during curtailment and maintenance periods. They usually
operate only one boiler at a time due to the contract for steam from W.E. Partners.
2D.0524 "New Sostree Performance Standards"Subpart Dc
Permit Condition 2.I.B.4.
The pemit condition assumes that Subpart De applies to the temporary boilers. 40 CFR 60.40c(i) states that
the subpart does not apply to temporary boilers. Valley Proteins has the option to remove the condition from
the permit with the next permit revision.
The condition states that the boilers are permitted to burn only natural gas. Valley Proteins last operated a
temporary boiler from March-September 2013 and December-March2014 while major maintenance was
conducted on the other boilers. There has been no temporary boiler on-site since March2014.
The permit condition requires notification within 15 days of actual startup.The condition requires the facility
to track monthly natural gas usage. They track fuel usage on a daily basis through the natural gas totalizer.
Valley Proteins is in compliance with 2D.0524.
2Q.0317"Avoidance Conditions"for
2D.0530 "Prevention of Significant Deterioration"
Permit Condition 2.I.A.4.
In order to avoid applicability of 15A NCAC 2D .0530(g)for major sources and major modifications,
boilers ES-8 and ES-9 are limited to the following emissions per consecutive 12-month period:
Pollutant '; ° Actual2-Yeah De,n%inimus Iepel PSD limit
Average ,°����� 1���! (tp
t
PM 16.2 25 41
PMro 13.15 15 28
4 6 40 215
S Sulfur dioxide 17 . 5 u
VOcs 0.37 40 40
Carbon monoxide 6.13 100 106
Nitrogen oxides 67.4 40 107
The packed tower scrubber is required to operate when the boilers are firing No. 6 fuel oil. It was my
understanding that Valley Proteins vents the boilers to this scrubber all of the time, but it was clarified
during the inspection that they do manually close the vent to the scrubber when the boilers are operating
on gas. Rob Fisher noted that the vent to the scrubber was closed during the inspection (on gas).
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C
Valley Proteins is required to calculate monthly sulfur dioxide emissions from all fuels. The facility is
also required to calculate monthly carbon monoxide emissions using AP-42 factors for the emissions
from fuel oil and natural gas combustion,and 0.0170 pounds per million Btu for the emissions from
saleable animal fat combustion. No fat has ever been combusted at this facility.
The facility is required to keep a record of the monthly emissions along with a record of the amount of
each fuel combusted. The records must also include verification that the packed tower scrubber operated
while No. 6 fuel oil was used. Valley Proteins did not have an official log for switching to scrubber use,
although it was confirmed with the boiler operator that it is a requirement in the SOP. I emailed a note to
Mike about the requirement and he created a new log for their boiler operator to check that the scrubber is
online when burning oil.A copy of the form is attached to the file copy of this report and saved to the
WaRO LAN. In CY2016 and CY2017 the facility has burned a negligible volume of fuel oil only during
boiler scheduled maintenance and inspection.Therefore,the absence of the records for packed scrubber
control during this period is not considered a compliance issue. Valley Proteins must ensure logs are
completed going forward.
Permit condition 2.LAA.g. requires the facility to submit semi-annual summary reports containing the
following information:
• the monthly sulfur dioxide emissions for the previous 17 months. The emissions must be
calculated for each of the 12-month periods over the previous 17 months.
• the monthly quantities of natural gas, saleable animal fats,and fuel oil consumed for the previous
17 months.
• the average sulfur content of the fuel oil
• the monthly carbon monoxide emissions from the previous 17 months. The emissions must be
calculated for each of the_12-month periods over the previous 17_months.
Valley Protein's gas totalizer is read on a daily basis, and the daily records are all recorded on a monthly
logsheet. A monthly sum is handwritten on each log. I compared the monthly totals in their records to
those reported to DAQ in the last two semi-annual reports, and the January-June 2017 totals were
reported a bit higher than the logs. Mike Anderson confirmed that Van Jones uses fuel totals provided by
Corporate Accounting for the emissions inventory and reporting.
Total reported CY2016 gas usage was 102,133 MCF. 684 gallons of No. 6 oil were combusted in the
boilers in 2016. Reported gas usage this year through June is 38,091 MCF.
The rolling annual total SOz emission has been negligible. CO rolling annual emissions have not exceeded
3.3 tons so far this year. The reports have been submitted on time. The reports are complete and demonstrate
compliance with the permit condition. Valley Proteins is in compliance with 2Q.0317.
2D.1111 "Maximum Achievable Control Technology"
Subpart JJJJJJ-NESHAP for Boiler Area Sources
Permit Condition 2.I.A.S.
This facility is a minor source of HAPs. Perdue submitted the initial notification for the boilers on 9/20/201 L
They resubmitted the initial notification on 7/12/2013 (to account for changes to the regulation). Permit
Condition 2.1.A.5. is written with the assumption that the boilers use multiple fuels. However,these boilers
have been operating on natural gas with fuel oil only used for maintenance and curtailment. As long as
boilers ES-8 and ES-9 meet the definition of a natural gas boiler as provided in the regulation,there are no
requirements under Subpart 6J. However,Valley Proteins has completed tune-ups and energy assessments
for the boilers, so they can burn oil whenever they wish.
The facility is required to perform biennial tune-ups of the boilers. Each tune-up must include the
following:
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• Inspection of the burner, anu cleaning/replacement of any components'_ the burner as necessary.
• Inspection of the flame pattern, as applicable, and adjustment of the burner as necessary to optimize
the flame pattern.The adjustment should be consistent with the manufacturer's specifications, if
available.
• Inspection of the system controlling the air-to-fuel ratio, as applicable,and ensurance that it is
correctly calibrated and functioning properly.
• Optimization of total emissions of carbon monoxide. This optimization should be consistent with the
manufacturer's specifications, if available.
• Measurement of the concentrations in the effluent stream of carbon monoxide in parts per
million, by volume, and oxygen in volume percent, before and after the adjustments are made.
The facility performs tune-ups at least a couple of times a year, but not all include every requirement under
6J. Perdue declared their 9/14/2015 tune-ups for both boilers as meeting the 6J requirements (which it does).
The most recent tune-up on ES-8 that meets 6J requirements was conducted on 2/16/2017. A copy of the
tune-up record is attached to the file copy of this report. ES-9 was shut down in November 2016 to replace
the tubes, so its tune-up will be associated with startup,which is allowed by the regulation.
Boiler maintenance is conducted according to weekly and monthly work orders,which I did review during the
inspection.
Valley Proteins submitted their Notice of Compliance Status on EPA's CDX-CEDRI database on 6/03/2014.
A hard copy of the CDX submittal is in the WARD file. The energy assessments were completed 10/20/2014,
with an update conducted on 5/27/2015. The energy assessment document is on file at the facility. Copies of
the cover page and table of contents are in the WaRO file.
Specific Condition 2.1.A.5.c.ii.C. requires documentation of the fuel used monthly by each boiler. Valley
Proteins is recording the fuel usage under permit Specific Condition 2.1.A.4.f.as well. Fuel consumption
records are complete.
_.
A biennial compliance certification is required starting 3/1/2015. The compliance certification must
contain the information specified in paragraphs 40 CFR 63.11225(b)(1)through (4) and must be
submitted upon request. The report must only be submitted to DAQ by March 15 if the facility has any
deviation described by paragraph(b)(3)of 40 CFR 63.11225. Otherwise the report is to be kept on file at
the plant. Valley Proteins completes this report annually. The certifications are on file at the facility. We
reviewed the 1/06/2017 certification, and it was complete.
Valley Proteins appears to be in compliance with 2D.1111 and NESHAP Subpart 6J.
Six poultry meal storage silos (ID Nos. ES-11 through ES-16),one poultry meal loadout
area (ID No. ES-19), and poultry meal conveyance(IES17)
Regulated ;, Limits[Standards` Applicable Regulation
Pollutant
Particulate Matter For process rates greater than 30 tons per hour: 15A NCAC 2D .0515
E= 55.0xP0`-40
Where: E=allowable emission rate in Ibs/hr
P=process weight in tons/hr
Visible Emissions 20 percent opacity 15A NCAC 2D .0521
2D.05I5 "Particulates from Miscellaneous Industrial Processes"
NO PERMIT CONDITION
These sources have been deemed insignificant, and are listed in the Insignificant Activities Attachment to the
permit. However,this rule still applies. See previous inspection reports for emissions estimations from the
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silos and loadout. Emissions from meal conveyance are expected to be negligible. The meal is very moist
and the system is covered. The insignificant sources are in compliance with 2D.0515.
2D.0521 "Control of Visible Emissions"
NO PERMIT CONDITION
Visible emissions from the silos,meal loadout, and meal conveyance must not exceed 20 percent opacity
when averaged over a six-minute period. Six-minute averaging periods may exceed 20 percent not more
than once in any hour and not more than four times in any 24-hour period. There were no visible
emissions observed from these sources during the inspection. The insignificant sources are in
compliance with 2D.0521.
2.2 -Multiple Emission Source(s) Specific Limitations and Conditions
Facility Wide Affected Sources
2D.0535 "Excess Emissions Reporting and Malfunctions"
Permit General Condition 3.La. and 3.LB.
Valley Proteins is required to report excess emissions from deviations or malfunctions that last more than
four hours. No malfunctions have been reported since the date of last inspection(August 2016).
Valley Proteins appears to be in compliance with 2D.0535.
2D.0539 "Odor Control of Feed Ingredient Manufacturing Plants"
Permit Condition 2.2.A.1.
We performed surveillance along Highway 308 north and south of the facility before(9:45 AM)and after
(1:50 PM) the inspection. We traveled north to Kelford each time. We also traveled down the access road
behind the plant before the inspection and Black Jack Road after the inspection. The morning temperature
was_79°F with mild breeze to the W/SW. The afternoon temperature was 85°F with a mild breeze to the
W/SW. We did not observe any odor during the surveillance. Note that the rendering plant was
intermittently operating during the day. Printouts of weather conditions for 7/26/2017 recorded by the closest
weather station are attached to the file copy of this report.
There was a mild rendering cooked odor as we pulled into the plant property. We observed the cooked odor
on-site during the entire inspection.
I also performed surveillance for odor at 8:00 PM on 7/10/2017. I briefly stopped in three spots along Hwy.
308 north of, next to and south of the plant. I did not smell any odor.
Cooked odor is usually a musty, slightly bitter smell. On warm,humid, and/or windy days, I have historically
smelled this odor leaving the property. Odor is also generated by the wastewater treatment system, which
supports both Valley Proteins and the Perdue chicken processing plant. However,the wastewater system is
owned and operated by Perdue. There are ponds with aerators located between the processing plant and
rendering plant. In my opinion the wastewater treatment system odor appears to be stronger and more
offensive than the cooked odor from the rendering plant. Wastewater odors are more likely prevalent in the
summer months when operating the aerators. Perdue staff are supposed to pay attention to wind direction
before running all of the aerators on really hot days. It is possible that the rendering plant cooked odor may
carry farther due to emissions coming from stacks.
There are residences on the other side of the tree line to the north that would be immediately affected by both
Valley Proteins and Perdue odors.
There should never be an issue with odor from unloading blood tanks since they constructed underground
piping from the tank to the anapond. If they had to perform an emergency unloading of a tank or if a tank
overflowed,they would use a suck truck to remove the blood. If a tank were to run over, the blood is fresh,
and I was told it would produce low odor.
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Mr.Anderson believes feathers nave more potential to produce odors,and L__ odors are likely better
controlled by processing the feathers in the cooler evening hours.
WaRO has not received a complaint call since the last inspection date in August 2016. Mr. Anderson said
that Valley Proteins has not received any odor complaints since I last inspected the facility. Mr.Anderson is
required by the company to call DAQ if they get an odor complaint. He must also personally investigate the
complaint. He said that he sometime will do surveillance as he comes and goes from the facility, including
driving down Black Jack Road.
When the state odor rule for rendering plants was promulgated,the facility wished to avoid having to comply
with the storage requirements for raw materials. To do so, they must make sure that all meat is processed in
less than 36 hours, all feathers are processed within 48 hours and all used cooking oil is unloaded within 96
hours(rule change from 24 hours storage, 9/30/2015, Session Law 2015-264, Senate Bill 513, page 12).
Otherwise,they must store the material in properly enclosed and vented areas that have odor control. Valley
Proteins has an electronic punch card system that tracks how long raw material loads are stored before being
dumped to processing. The weigh scale tags truck delivery and departure. The scale is calibrated semi-
annually. They have a limited number of trailers, so they have to dump loads quickly so the trailers can
adequately serve the customer. The computer program will change the color for a load record as it ages to
alert operators that it needs to be processed. The worst case is a red tag at 14 hours.
Chicken necks and feet get processed slower because the bone must be mixed a little at a time with the
other meat. No raw material is usually allowed to just sit on the pad indefinitely. MDM(mechanically
deboned material)may sometimes be on the pad for 12-14 hours,as well as poorly cooked material that is
blended back into the raw material on the front end(which is usually reprocessed within 3 hours). There
are usually about 5-6 loads of MDM raw material sent off-site for processing each week. Wet feathers
may also be pushed onto the pad for a short while to drain before going into the bay.
- -- —T-ime-card-data is reviewed-weekly-and-separate reports are kept of loads-that-exceeded-or-appeared-to-exceed-
24 hours (they have kept this as a limit to ensure they always meet the rule requirements). Rob Fisher
reviewed all of the 24-hr exceedance records from August 2016 to July 2017. No loads exceeded the 36-hr
threshold.
Rob Fisher also reviewed the complete time card records for November 2016 and April 2017(which are
saved to the WaRO LAN).There were a few loads that required follow up questions for Mr. Anderson(see
attached copies of emails). He provided additional information on 8/07/2017,and there were no compliance
problems with the loads.
Normal loads approaching the hours limitation may be backed into the loading bays so that the room air
vacuum could pull air across the trailer into the crossflow scrubber. I talked to Robert Hayden with FRO
about this practice(they have a couple of Valley Protein facilities in the region) following my August 2014
inspection. NCDAQ has accepted this method of storage as acceptable under the rule. The facility tries to
avoid implementing this practice,but the records indicated three loads have been sheltered since August 2016.
There are time card exceedance records for grease tanker truck unloadings mixed in with the raw material
loads. However,their trucks unload to a closed system that are not regulated under 2D.0539. More
refrigerated trucks have been delivering in the last year,due to some backlog in processing. These trucks are
exempt from the 36-hr clock. All other time card exceedance loads were MDMs or regular loads that were
rejected and shipped off-site in under 36-hours. Shipping tickets from the receiving plant are attached to
those records, proving the time the loads left the site.
2D.0539 requires that their raw material trucks be tarped while in transport. Trailers containing raw
material sit near the receiving pad behind the office building. Empty trailers are stored in the open yard in
front of the plant. The rule does allow for uncovered raw material as long as it was generated on-site at
the Perdue processing plant. During the inspection we observed that all trucks on-site had scroll covers.
Mike confirmed that the trucks containing a full load ready to be dumped came from Perdue next door.
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Once a trailer dumps into the receiving bay, it is washed. This is a potential source of odor.
It is my understanding that as long as building pressure is negative,the loading bay doors to the rendering
plant do not have to be closed all of the time. They usually like to keep the large scroll doors open about
halfway, but will open the roller doors all the way on very hot days. During the inspection the large scroll
doors to the plant were open half-way. We stood in front of the door next to the packed scrubber. The
room air pressure seemed to be slightly positive, but we did not smell any odors. At the boiler room
doors room air appeared to be negative.
The rule requires Valley Proteins to send process gases through condensers to remove all steam and other
condensable materials. The rule requires control of expeller(press)gases.All noncondensible gases are to
be incinerated at 1,200 degrees Fahrenheit for a period of not less than 0.3 seconds, or treated in an
equally effective manner. DAQ has approved control of process gases with operation of a condenser,
venturi scrubber and packed scrubber.The presses are hooded and ducted to scrubber control. Room air
goes to the crossflow scrubber.
Permit conditions 2.2.A.l.c.ii. and iii.require Valley Proteins to use a scrubbing binder in the cross flow
and packed bed scrubbers(CD-1 OD and CD-I OF)daily from March 1 through September 30 of each year,
and to add the binder weekly with each water flush. Permit condition 2.2.A.I.e.ii. requires the facility to
keep a record of when the binder is added. I reviewed the records back to August 2016,and they were
complete. Valley Proteins is adding binder every week,all year. The add dates are recorded on both the
packed scrubber weekly cleanout logs and the crossflow scrubber daily gpm logs.
B-10 binder is a black liquid that smells like pine sol. It is supposed to be a self-sustaining,regenerating
biological. It enhances the ability of the water to trap noncondensibles at higher temperatures. Only
about 8 oz. is required per charge.
The Valley Proteins Quality Assurance Plan is in the WaRO file. It has been updated since the last inspection.
The plan mirrors permit requirements and references use of the O&M manuals for plant equipment to satisfy a
quality assurance program. In addition to the plan Valley Proteins conducts annual corporate environmental
audits. An annual audit had been coincidentally completed the day before our inspection on 7/25/2017.
Conditions 2.2.A.Lb. and c. contain monitoring requirements for the scrubbers:
• semi-annual inspection of crossflow scrubber spray nozzles and perform maintenance and repair
when necessary to assure proper operation of the scrubber,
• monthly inspection, cleaning, and calibration of all associated instrumentation,
• semi-annual external inspection of the venturi scrubber,crossflow scrubber and packed scrubber
for structural integrity,
• weekly cleanout of the packed bed scrubber; and
• install, operate, and maintain a liquid flowmeter on the crossflow scrubber. The liquid flow rate
into each stage of the scrubber shall be no less than 500 gallons per minute of water, or water and
additives.The flows must be recorded daily.
I reviewed records for all the above monitoring back to August 2016. The records were complete, and
monitoring has been satisfactorily conducted. Example records are attached to the file copy of this report.
They perform external inspection and weekly cleanouts on all three scrubbers, as well as weekly fan
maintenance checks on all three scrubbers. The crossflow scrubber spray nozzles are inspected weekly.
All of the scrubber fans,pumps and ducts have monthly mechanical maintenance and cleanouts. The
packed scrubber is drained and washed weekly. The packed scrubber is opened every couple of months
to add a detergent cleaner.
It is my understanding if the crossflow scrubber flow gets below 525 gpm, it's time to replace the pumps.
The flowmeters have been changed out annually. At least one new flowmeter is kept available on-site.
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The most recent replacements all flowmeters were on 5/29/2016. The i ✓meters are checked daily
for mechanical issues.
The daily crossflow scrubber flow measurements were complete. The crossflow scrubber flowmeters
read 550 gpm and 575 gpm during the inspection. Air flow through the crossflow scrubber is
approximately 60,000 cfm. Flow on the packed bed scrubber is also recorded every day. The gauge read
400 gpm during the inspection.
The facility must submit a semi-annual summary report for all monitoring requirements. The reports have
been on time and complete. Valley Proteins appeared to be in compliance with 2D.0539.
2D.0540 "Particulates from Fugitive Non process Dust Emission Sources"
Permit General Condition 3.MM.
The facility may not generate fugitive dusts that go beyond the property boundary and cause a substantive
complaint. Fugitive emissions are those that don't pass through a stack or vent, and are generated within
plant property boundaries. The primary dust fugitives from Valley Proteins come from truck traffic. We did
not see any fugitive dust leave the property boundary during the inspection.
2Q.0207"Annual Emission Inventory Requirements"(Condition 2.3.X.)
The facility must submit an annual emissions,inventory by June 3011 each year. The accuracy of the report
must be certified by a responsible official of the facility. The CY2016 inventory was submitted
electronically on 5/30/2017. The certification and hard copy forms/calculations were received on
6/02/2017. I have reviewed and approved the CY2016 inventory on 8/07/2017.
2Q.0508(n) "Compliance Certification"(Condition 2.3.P.)
The facility is required to submit an annual compliance certification to the DAQ and EPA Region 4 on or
before the first of March. The certification covers all federally-enforceable terms and conditions in the
permit, including emissions limitations, standards, or work practices for the previous calendar year. It must
- -- be-signed-by-a-responsible-official.-DAQ received the 2016 ACC postmarked-on-4/2 412 0 1 7.-I-reviewed-and
approved the report.
Monitoring, Recordkeeping and Reporting (MRR)
All permit-required records were reviewed back to August 2016. Valley Proteins'reports have been
submitted on time. I have reviewed the reports and have determined that they are complete. There were no
compliance issues discovered in the reports. The MRR requirements are listed in the table below.
Monitoring/Recordkeeping Re uirement MRR Frequency Regulation Report Required?
Fuel oil certifications must be<2.1%sulfur) Each shipment 2D.0516 Certifications
Boiler visible emissions oil combustion only) Weekly 2D.0521 SA Deviation report
Boiler scrubber operation while firing oil As applied 2Q.0317 No
Nat gas/fuel oil/fat used in ES-8 and ES-9 Monthly 2Q.0317 for Monthly fuel amts
(PSD Avoidance)-No fat has ever been burned 2D.0530 and and 12-month rolling
2D.1 I I I totals SO2 and CO
Subpart 6J bi-annual boiler tune-ups and compliance Bienniel 213.1111 No
certification
Temporary Boiler initial notifications(NSPS Dc) Win 15 days of startup 2D.0524 No
Temporary Boiler natural gas usage(NSPS Dc) Monthly 2D.0524 No
Rendering truck punch cards for load processing Per load(time of receipt and time of 213.0539 SA Deviation report
unloading)
Crossflow scrubber I&M Semi-annual nozzle inspection 2D.0539 SA Deviation report
Venturi scrubber CD-10E and packed scrubber CD-1OF Semi-annual external inspection 2D.0539 SA Deviation report
All scrubbers Monthly instrumentation inspection 2D.0539 SA Deviation Report
Add scrubbing binder weekly March ls'-September 3011h Record dates of binder addition 2D.0539 SA Deviation report
Crossflow scrubber flow rates(must be>500 m) Dail 2D.0539 SA Deviation re ort
Ma ntenance to book for all scrubbers Com lete as work is conducted 2D.0539 SA Deviation report
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Enforcement History
Valley Proteins has no enforcement history,but the following NOD's have been issued in the last five years:
8/25/2014-2D.0539(f),Specific Condition 2.2.A.1.
Eighteen raw material truck loads that were processed more than 24 hours after delivery.
• 2/06/2015-2D.0539(f),Specific Condition 2.2.A.1.
Five raw material truck loads on 7/10/2014, 7/12/2014 and 8/13/2014 were processed more than 24
hours after delivery.
• 8/27/2015-2D.0521,Specific Condition 2A.A.3.d.
Weekly visible emissions observation during fuel oil combustion on January 8, 2015 and January 9,
2015 could not be provided during inspection.
Comments/Conclusions
Based upon visual observation and records review,the facility appeared to operate in compliance with the
conditions of the permit at the time of the inspection.
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