AQ_F_0800081_20180831_CMPL_InspRpt (4)

NORTH CAROLINA DIVISION OF Washington Regional Office
AIR QUALITY Valley Proteins-Lewiston Division
NC Facility ID 0800081
Inspection Report County/FIPS:Bertie/015
Date: 09/11/2018
Facility Data Permit Data
Valley Proteins-Lewiston Division Permit 03085/T32
222 Griffins Quarter Road Issued 1/29/2018
Lewiston-Woodville,NC 27849 Expires 12/31/2022
Lat: 36d 8.4040m Long: 77d 13.4680m Classification Title V
SIC: 2048/Prepared Feeds Nee 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
MACT Part 63: Subpart 6J
C.Anderson C.Anderson Robert Vogler NSPS: Subpart Dc
General Manager General Manager Director of
[phone] [phone] Environmental Affairs
[phone]
Compliance Data
Comments: The facility appeared to operate in compliance with the permit
conditions at the time of the inspection. A NOD will be issued for reported raw Inspection Date 8/03/2018 and 8/31/2018
material meat loads that were processed more than 36 hours after delivery. Inspector's Name Betsy Huddleston
Operating Status Operating
Inspector's Signature: Compliance Code Compliance-inspection`4" "
Action Code FCE
p—� On-Site Inspection Result Violation
Date of Signature: 9�i Z�>3� 911 8'1
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2017 0.3400 0.1600 5.04 20.22 4.18 0.3000 178.90
2016 0.3800 0.0700 5.22 23.49 4.37 0.3400 187.15
2015 0.7900 1.26 4.67 17.04 3.46 0.7200 142.54
*Hi test HAP Emitted inpounds)
Five Year Violation History:None
Performed Stack Tests since last FCE: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 third stoplight,turn left onto Highway 308 West.
• Stay on Highway 308 to Lewiston Woodville. The plant is located behind the Perdue chicken
processing plant which is on the left side of the aoad 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 frequently 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(ID No. CD-1 OF)to control emissions from the boilers when combusting oil
and to reduce odor from the process equipment emissions.
• 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-11 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"
• T32 was issued on 1/29/2018 for permit renewal. The truck load processing time limits were
updated in this permit revision per Session Law 2015-263.
• A tax certification was issued to Valley Proteins on 4/09/2018 for replacement of the framing for
both the crossflow and packed bed scrubbers.
Process Description
1. Meat/feather trucks dump at the receiving pad. There are three raw material bays(two are for meat
and one is for feathers). There is also a grease hopper that is used for recycling tank bottoms
(cleanout). The material is carried by conveyor and trash is removed. Bone is delivered in
refrigerated trucks. Bone waste is metered into the meat mix. Grease and blood are delivered and
unloaded from enclosed containers.
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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.Time cards are also kept for bone, grease and blood loads.
4. The meat goes to the preheater or bypasses to the dual cooker. Most of 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 conveys from the preheater to either cooker,but 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.
11. Presses#1 and#3 feed to a bin and then a grinder. Presses#2 and#4 also feed to a bin and 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.
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.
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The sources and control devices at the facility are listed on the permit in the following format.
ES-8 and Two natural gas/saleable CD-10F One packed bed scrubber(288 to 575 gallon
ES-9 animal fat/No. 6 fuel oil-fired per minute normal operating range)utilizing
boilers (84 MMBtu/hr max water, air,and filter media to reduce PM and
GACT, heat input capacity,each) S02 emissions in the boilers and also used
Subpart 6J conditionally for additional control of
noncondensibles depending on fuel fired in
the boilers for the poultry processing
equipment
ES-23 and Two natural gas-fired NA NA
ES-24 temporary,back-up boilers
(less than 90 MMBtu/hr max
heat input capacity, each)
ES-10A.1* One poultry by-product cooker CD-10E One venturi wet scrubber(voluntary for odor
and one dual-use control state-only requirement)
feather/poultry by-product
cooker(ID No. ES-10A.1),
or
ES-10A.2*, and One feather dryer and one CD-lOD One two-stage crossflow wet scrubber(500
hydrolyzer(ID No.ES-10A.2), gallons per minute nominal liquid injection
and rate per stage)and a dry filter mist eliminator
or
ES-10E* Two liquid/fat evaporators CD-1 OF One packed bed scrubber(288 to 575 gallon
(ID No. ES-lOE) per minute normal 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
ES-1 OB* Poultry by-product presses and CD-lOD One two-stage cross flow wet scrubber(500
preheater(11)No. ES-1 OB), gallons per minute nominal liquid injection
and rate per stage)and a dry filter mist eliminator
or
ES-1 OD* Process room air collection CD-1 OF One packed bed scrubber(288 to 575 gallon
(ID No. ES-1 OD) per minute normal 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
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The following insignificant sources are listed in the permit attachment. There is one cooling tower that
may eventually need to be added to the list.
IES 17 Poultry meal conveyance system
I-WCCS Wastewater collection and conveyance system
IES-11, IES-12,IES-13, Six(6)meal storage silos(ES-11 and ES-14 are 300
IES-14, IES-15, and IES-16 tons capacity and the rest are 100 tons capacity)
IES-19 Meal loadout area(54 tons per hour capacity)
It should be again noted that the cookers,feather dryer,feather hydrolyzer,presses, preheater,and
evaporators are actually controlled 24/7 by the venturi and packed bed scrubbers. Valley Proteins
does not take advantage of the conditional use made available by the permit source table above.
Only the room air vents exhaust to the crossflow scrubber.
Inspection Observations and Regulatory Review
Sam Mellott and I performed a physical inspection of the rendering plant and a partial permit records review
on 8/03/2018. The inspection was performed using the current Title V permit(T32). The inspection was
completed with assistance from Mr. Mike Anderson(plant manager). Following our visit,Valley Proteins
provided requested raw material load processing records on 8/06/2018 by email. Review of these records was
not completed until 8/31/2018 after several questions were answered in email by Mike Anderson.
No issues were observed with the sources and control devices during the inspection. There were no holes
or tears observed in the ductwork or control devices.
The packed scrubber is filled with stainless media. Mr.Anderson previously noted that airflow to the
packed scrubber is approximately 86,000 ACFM.
The plant generally operates on Saturdays and Sundays if there are overflow loads or backlogged loads.
However, for the last several months,they have been operating on weekends due to increased deliveries
(other plants have been having issues). Most of the meat and feathers are supplied by the Perdue
processing facility next door, but they do receive many loads from other facilities each day. I confirmed
with Mr. Anderson that in the previous twelve months the No.I meat cooker has continued to operate
mostly afternoon and at night(with the No. 2 meat cooker serving as secondary). Feathers are processed
round the clock with 3-4 down hours per day.
Both cookers were operating at the beginning of the inspection,but the#1 cooker went down while we
were completing the physical inspection of sources.
Note that one of the evaporators has not been in use for the last couple of years. During the physical
inspection of the sources and control devices,we observed the packed scrubber flowmeter reading at 550
gpm. We also observed the crossflow scrubber flowmeters reading at 550 gpm and 600 gpm.
Valley Proteins installed a new plant-wide control system earlier this year. The system still does not
automate feed, and there are still a number of other manual controls.
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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 D Nos. ES-23 and ES-24
Particulate matter 0.27 pounds per million Btu heat in7(ES-23)
d ES-9) 15A NCAC 2D .0503
0.25 pounds per million Btu heat inp0.23 pounds per million Btu heat inp
Sulfur dioxide 2.3 pounds per million Btu heat input 15A NCAC 2D .0516
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 .I I I I
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)to supplement. On a continuous full operation day the steam demand can be as
much as 75,000-80,000 lbs/hr. Mr.Anderson said the W.E. Partners has been operating well,with little
downtime. When it is down,Valley Proteins can operate both of their boilers as needed. In the last 12
months the most hours W.E. Partners has been down during a month while Valley was operating occurred
during April 2018 (97 hours).
ES-9 was operating during the inspection,while ES-8 is undergoing a tube and wall replacement. Boiler ES-
9 had its tubes and wall replaced beginning November 2016. We observed the boiler pressure at 131.3 psi,
and stack temperature was 328°F. The boiler was firing natural gas. We saw no visible emissions from the
stack.
No temporary boilers have been brought on site since DAQ's last inspection on 7/26/2017.
2D.0503 "Particulates from Fuel Burning Indirect Heat Exchangers"
Permit Conditions 2.I.A.1. and 2.1.B.1.
The boilers have never been tested for particulate. There has been no gas curtailment since DAQ's last
inspection on 7/26/2017.
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 lb/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/151,000 Btu)(24 lb/1000 gallons)= 14.05 lbs/hr emitted
14.05 lbs/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/MMBtu. There are no monitoring/recordkeeping/reporting(MRR)conditions for
2D.0503. Valley Proteins is in compliance with 2D.0503.
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2D.0516 "Sulfur Dioxide Emissions from Combustion Sources"
Permit Conditions 2.I.A.2. and 2.LB.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 gas 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, and that shipment was compliant. Valley Proteins has submitted complete
semi-annual reports on time. Valley Proteins is in compliance with 2D.0516.
2D.0521 "Control of Visible Emissions"
Permit Conditions 2.I.A.3. and 2.I.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-9 during
the inspection(just heat waves).
There are no monitoring/recordkeeping/reporting requirements for the temporary boilers.
When No.6 fuel oil is combusted, emissions are vented to the packed scrubber, which creates a very
visibly wet plume. Therefore, alternative monitoring has been required to demonstrate compliance with
the visible emissions limit. Until 1/29/2018 Permit Condition 2.1.A.3.d. required weekly visible
emissions observation on ES-8 and ES-9 when combusting No. 6 fuel oil. Valley Proteins tries to fire
fuel oil only for gas curtailment and maintenance. Since DAQ's last inspection date of 7/26/2017 fuel oil
has been combusted on 12/23/2017 (294 gallons for tune-up), 12/24/2017(443 gallons for tune-up), and
one day in March 2018 (317 gallons for tune-up). There were visible emissions observation records for
the December dates, and they indicated no opacity. Because the oil was used for tune-ups,the scrubber
was not employed while it was burned. They needed to see the direct stack emission as part of the tune-
up. This is an acceptable practice for maintenance time-up. Their fuel records are attached to the file
copy of this report.
With issuance of permit T32 on 1/29/2018, Permit Condition 2.1.A.3.d. was modified to require the
following activities associated with the packed tower scrubber:
• Emissions from the boilers must be controlled at all times by the packed bed scrubber when
combusting fuel oil(see the note about tune-ups exception).
• Perform semi-annual external inspection of the packed bed scrubber.
• Record the scrubber flow rate at least once per day and verify that the flow rate is within the
manufacturer's specifications.
• Perform weekly cleanouts of the scrubber and monthly instrumentation inspections.
• Scrubbing binder must be in use daily from March I"through September 301 each year.
• Binder must be added weekly.
The records were reviewed for the above tasks, and they were complete. Even with the change to the
condition,Valle Proteins is still doing a weekly VE observation for their boilers while firing natural gas.
Valley Proteins is in compliance with 2D.0521.
I5A NCAC 02Q.0317.Avoidance Conditions for
2D.0524 "New Source Performance Standards"Subpart De
Permit Condition 2.I.B.4.
To avoid applicability of NSPS, any temporary boiler must meet the following requirements
• Meet the definition of a temporary boiler under NSPS 60.41 c.
• Ensure that the boiler rating doesn't exceed 90 MMBtu/hr.
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• Only fire natural gas.
• Keep records demonstrating that the boiler(s)is not on-site for more than 180 consecutive days.
No temporary boiler has been used since last DAQ inspection in July 2017. Valley Proteins is in
compliance with the permit condition.
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:
PM 16.2 25 41
PMI0 13.15 15 28
Sulfur dioxide 174.65 40 215
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. Since DAQ's
last inspection date of 7/26/2017 fuel oil has been combusted on 12/23/2017(294 gallons for tune-up),
12/24/2017(443 gallons for tune-up), and one day in March 2018 (317 gallons for tune-up). Because the
oil was used for tune-ups,the scrubber was not employed while it was burned. This is considered an
acceptable practice.
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.
Permit condition 2.1.AA.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. In addition,Mr.Van Jones uses fuel totals
provided by Corporate Accounting for the emissions inventory and reporting.
Total reported CY2017 gas usage was 99,341 MCF. 1,9881 gallons of No. 6 oil were combusted in the
boilers in CY2017. Reported gas usage this year through June is 100,040 MCF.
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The rolling annual total S02 emission has been negligible. CO rolling annual emissions have not exceeded 7
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 Z LA.S.
This facility is a minor source of HAPs. Perdue submitted the initial notification for the boilers on 9/20/2011.
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 bum oil whenever they wish.
The facility is required to perform biennial tune-ups of the boilers.Each tune-up must include the
following:
• Inspection of the burner, and cleaning/replacement of any components of 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. The facility declared the 9/14/2015 tune-ups for both boilers as meeting the 6J requirements(which it
does).Valley Proteins did complete tune-ups in 2017. We reviewed the records and they are complete.
Boiler maintenance is conducted according to weekly and monthly work orders,which we 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.
Valley Proteins appears to be in compliance with 2D.1111 and NESHAP Subpart 6J.
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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)
Particulate Matter For process rates greater than 30 tons per hour: 15A NCAC 2D .0515
E=55.0xP011-40
Where: E=allowable emission rate in lbs/hr
P=process weight in tons/hr
Visible Emissions 20 percent opacity 15A NCAC 2D .0521
2D.0515 "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
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. At the time of our visit at the plant on 8/04/2018 no malfunctions had been reported since the
date of last DAQ inspection(7/26/2017). However, on 8/23/2018 Valley Proteins reported that the
crossflow scrubber fan had failed that day. Metal fatigue caused the fan blades to hit the housing and
break. They ordered a replacement and had it in operation on 8/27/2018.However,the replacement fan
failed at about midnight on 8/28/2018. They were able to get a temporary fan installed and running on
9/03/2018. The crossflow scrubber was down for approximately 11 days. I have completed a
2D.0535 "NC DAQ Excess Emissions Form"and submitted to Rob Fisher, Regional Supervisor for
review and agreement of the fan failure as a malfunction.All email correspondence associated with the
scrubber fan failure are attached to this form. Valley Proteins is considered in compliance with
2D.0535.
2D.0539 "Odor Control of Feed Ingredient Manufacturing Plants"
Permit Condition 2.2.A.1.
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. West Berrie Elementary School is located nearby on North Highway 308.
I performed odor surveillance along Highway 3,08 north and south of the facility and along Black Jack Road
before the inspection. Temperature was 74°F. There was mild"cooked"odor on Highway 308 in front of the
Perdue plant,but I could not detect any odor on Black Jack Road. Both Sam Mellott and I performed odor
surveillance along the same roads after the inspection at about 3:30 PM. The temperature was 82°F, and the
wind direction was coming from the south/southwest. We both smelled mild,musty"cooked"odor along
Black Jack Road.
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There was raw material and cooked odor onsite as we conducted the physical inspection of the facility sources
and controls.
I also performed surveillance for odor with Kurt Tidd at 12:00 PM on 8/28/2018 along Highway 308 and
Black Jack Road,while the crossflow scrubber was down(see discussion in 2D.0535 section above). The
temperature was 89°F, and the wind direction was from the south/southwest. We both smelled noticeable
"cooked" odor along Highway 308 in front of the Perdue Plant up to the residence at 3616 Hwy 308. No odor
was detected at the elementary school. We did not detect any odor along Black Jack Road.
Cooked odor is usually a musty, slightly bitter smell. On warm,humid, and/or windy days,I have historically
smelled it off-site. The cooked odor is coming from the scrubber stacks, so can be dispersed with wind
direction. 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. 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.
There should never be an issue with odor from having to dump 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.
Mr.Anderson believes feathers have more potential to produce odors,and the odors are likely better
controlled when processing the feathers in the cooler evening hours.
WaRO has not received a complaint call since the last inspection date on 7/26/2017. Mr.Anderson said that
Valley Proteins has not received any odor complaints since then as well. Mr.Anderson is required by the
company to call DAQ if they get an odor complaint. He must also immediately personally investigate the
complaint by going to the location of the complaint to evaluate. He said that he sometimes 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(per rule change on 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. Poorly cooked material
(called"greasy meal")that is blended back into the raw material on the front end may sit on the pad, but
is usually reprocessed within 3 hours. Wet feathers may also be pushed onto the pad for a short while to
drain before going into the bay. During our inspection we noticed piles of feathers on the pad. Mr.
Anderson said the piles contained some `contamination,' so they were blending the feathers into `clean'
loads. He noted that the piles were only going to be on the pad for a few hours(gone by 3:00 PM).
MDM(mechanically deboned material) is composed of bone hash that robs protein from the meal and
creates ash in the cookers. Valley Proteins has installed a bin for MDM to avoid putting it on the pad.
They meter it from the bin to the pit. They now send 10 loads of MDM raw material off-site for
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processing elsewhere each week.
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 they do employ it when necessary.
Time card records for grease tanker trucks and blood tanks may be disregarded because those trucks unload to
closed systems not regulated under 2D.0539. Refrigerated trucks are also exempt from the 36-hr clock.
Trash truck time cards may be disregarded because the trash is not rendering plant raw material, it is normal
landfill solid waste. Sludge is a waste material that comes out of the wastewater system. It has fat in it. It is
pumped in an enclosed system to an enclosed truck and sent off site for fat recovery. Timecards for sludge
may be disregarded.
Many 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 Lewiston site.
Time 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. Mr.Anderson
noted that it has been a challenge in the last few months to process all loads in under 24 hours due to increase
in production and increased loads delivered as a result of breakdowns at other plants.
Sam Mellott and I reviewed all of the 24-hr exceedance records from August 2017 to July 2018. I requested
that all load records from January 2018 through July 2018 be emailed to us. Kelly Gauthreaux emailed them
to me on 8/06/2018. The spreadsheet is saved to Sharepoint at
https://ncconnect.sliarepoint.com/sites/deq/daq waro/Sbaredl/o20Documents/ Facilities/Bertie08/00081/AQl
6s/January-July%202018%20timecards.xlsx. Sam and I completed review of those records on 8/31/2018,
completing the annual inspection.
From the review of the above records,the following loads were identified to exceed the regulatory processing
limits for meat(36 hrs)or feathers(48 hrs):
Load Receipt Date Load ID Number Material Processing Time Reason
6/11/2018 12613747 MDM 37 hrs, 15 minutes Backlog,unable to move
to another facility
6/12/2018 12614248 MDM 36 hrs,3 minutes Backlog,unable to move
to another facility
6/12/2018 12614657 Skin 36 hrs,41 minutes Backlog,unable to move
to another facility
6/18/2018 12619797 MDM 36 hrs, 32 minutes Backlog,unable to move
to another facility
Valley Proteins reported four dates(6/11/2018, 6/14/2018, 6/28/2018,and 6/30/2018) in their semi-annual
summary report associated with overdue loads. Mr.Jones did not qualify whether the dates were for receipt
of loads or process completion. Sam and I only found the above loads in excess of the processing limit. I will
request that Valley begin to list the information as it is supplied above in future deviation reports. Because
the above listed loads were processed not long after the limit,WaRO will issue a NOD to Valley Proteins.
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.
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One truck containing feathers was uncovered,but it came from Perdue next door. Other uncovered trucks
onsite appeared to be empty. Once a trailer dumps into the receiving bay,it is washed with hot water.
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. It is corporate policy to keep the large scroll doors open
knee to belt level. As we walked out of the process building and boiler room air flow did appear to
indicate negative pressure.
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-1 OF) daily from March 1 through September 30 of each year,
and to add the binder weekly with each water flush. B-10 binder is a black liquid that smells like pine sot.
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. Permit condition
2.2.A.l.edi.requires the facility to keep a record of when the binder is added,along with daily crossflow
scrubber flows. We reviewed the records back to July 2017, 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. Binder addition is also noted in the weekly
nozzle inspection reports.
The Valley Proteins Quality Assurance Plan is in the WaRO file. It has not 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 was recently completed in late July 2018.
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.
We reviewed records for all the above monitoring back to July 2017. The records were complete, and
monitoring has been satisfactorily conducted. They perform weekly 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.
They perform monthly flowmeter calibration checks.
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They perform monthly flowmeter calibration checks. The flowmeters are sent out for re-calibration or
replaced annually,most recently 9/25/2017 and 8/01/2018 for the crossflow scrubber, and 12/07/2017 and
6/17/2018 for the packed scrubber. At least one new flowmeter is kept available on-site. The flowmeters
are checked daily for mechanical issues.
The daily crossflow scrubber flow measurements were complete and compliant. Air flow through the
crossflow scrubber is approximately 60,000 cfm. Flow on the packed bed scrubber is also recorded every
day. They try to maintain a minimum 400 gpm on the packed scrubber.
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 2.3X)
The facility must submit an annual emissions inventory by June 301 each year. The accuracy of the report
must be certified by a responsible official of the facility. The CY2017 inventory was submitted
electronically on 5/30/2018. The certification was received on 6/01/2018. I have reviewed and approved
the CY2017 inventory on 7/17/2018.
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 2017 ACC postmarked on 1/30/2018. I have
reviewed and approved the report.
Monitoring, Recordkeeping and Reporting (MRR)
All permit-required records were reviewed back to July 2017. Valley Proteins' reports have been submitted
on time. With exception of a minor issue with the most recent semi-annual reporting of overdue loads
(discussed under 2D.0539 above), the reports are complete and compliant. The monitoring,recordkeeping
and reporting requirements in the permit are summarized below.
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Monitoring/Recordkeeping Requirement MRR Frequency Regulation Report Required?
Fuel oil certifications must be<2.1%sulfur Each shipment 2D.0516 Certifications
Packed scrubber operation while firing oil,scrubber As applied 2Q.0317 SA Deviation report
daily flow recorded
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.1I I I totals SO2 and CO
Subpart 6J bi-annual boiler tune-ups and compliance Bienniel 2D.I I I I No
certification(only if they burn outside curtailment or
maintenance
Temporary Boiler days of operation<180 days Record at end of operation period 2D.0524 No
Rendering truck punch cards for load processing Per load(time of receipt and time of 2D.0539 SA Deviation report
unloading)
Crossflow scrubber I&M Semi-annual nozzle inspection 2D.0539 SA Deviation report
Venturi scrubber CD-IOE and packed scrubber CD-IOF Semi-annual external inspection 2D.0539 SA Deviation report
All scrubbers Monthly instrumentation inspection 2D.0539 SA Deviation Report
Add scrubbing binder weekly March 14-Se tember 301h Record dates of binder addition 2D.0539 SA Deviation report
Crossflow scrubber flow rates must be>500 m Daily 2D.0539 SA Deviation report
Maintenance logbook for all scrubbers Complete as work is conducted 2D.0539 SA Deviation report
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 2.1.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.
A NOD will be issued for four meat product loads that were processed more than 36 hours after delivery in
June of 2018. The facility self-reported in their semi-annual deviation report.
Comments/Conclusions
The facility appeared to operate in compliance with the permit conditions at the time of the inspection. A
NOD will be issued for reported raw material meat loads that were processed more than 36 hours after
delivery.
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