AQ_F_0400034_20170629_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY Valley Proteins,Inc. -Wadesboro Division
NC Facility ID 0400034
Inspection Report County/FIPS:Anson/007
Date: 07/03/2017
Facility Data Permit Data
Valley Proteins,Inc. -Wadesboro Division Permit 06467/T18
656 Little Duncan Road Issued 10/3/2011
Wadesboro,NC 28170 Expires 9/30/2016
Lat: 35d 2.1192m Long: 80d 4.9683m Classification Title V
SIC: 2077/Animal And Marine Fats And Oil Permit Status Active
NAILS: 311613 /Rendering and Meat Byproduct Processing Current Permit Application(s)TV-Renewal
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP/Title V
MACT Part 63: Subpart 6J
Chris Bivans Chris Bivans Robert Vogler NSPS: Subpart Dc
General Manager General Manager Director of
[phone] [phone] Environmental Affairs
[phone]
Compliance Data
Comments:
Inspection Date 06/29/2017
Inspector's Name Joshua L.Harris
Inspector's Signature: Operating Operating Status Operating
Compliance Code Compliance-inspection
Action Code PCE
Date of Signature: d»/4X/4017 ,u On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR: hIJ
TSP S02 NOX VOC CO PM10 * HAP
2015 2.33 0.3000 28.06 18.71 21.82 2.33 930.00
2014 2.09 0.1700 27.38 17.65 22.86 2.09 979.00
2013 1.92 3.40 24.15 13.66 19.84 1.88 844.14
* Highest HAP Emitted(inpounds)
Five Year Violation History:None
Date Letter Type Rule Violated Violation Resolution Date
Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested

I. MACT/GACT: The facility is subject to GACT 6J,though this is not currently in the permit. The
facility completed the one-time Energy Assessment on 07-08 November 2013, submitted the NOCS on
03 June 2014,and is conducting boiler tune-ups semiannually with the last tune-ups being performed on 23
January 2017. A copy of the biennial certification was on-site, and was prepared on time.
H. DIIIECTIONS TO SITE: From FRO,take US 401 South through Wagram. South of Wagram,take
Old Wire Road(NC 144)to US74. Follow US 74 west through Wadesboro,and turn right(north)onto US52.
Go a few miles,pass Triangle Brick on right, go ''A mile,and the entrance to the Valley Protein plant is on the
right. Proceed down the road to the driveway to the office building on the left side of the parking
lot/driveway.
III. SAFETY: Hard hat, safety glasses, safety boots,hearing protection; gloves and a wipe rag are
advisable. The greatest hazard to the inspector is either slipping on stairs, or burn from a leaking steam pipe.
Steam is used extensively,and there are always puddles that reduce boot traction. An inspector is consciously
or subconsciously tentative about touching railing at a rendering plant,which could increase the chance of
falls. Keep fingers out of your mouth during the inspection, and wash hands thoroughly when finished.
IV. FACILITY DESCRIPTION: The facility renders chicken feathers,and fat for a number of
processors. Currently,blood and offal are sent to other plants.They use several rendering methods to make
four products: feather meal,pet-food-grade protein meal, feed-grade meal(poultry food additive),and two
grades of fat. The majority of the fat is sold as a feed additive but can also be used as boiler fuel when fuel
prices warrant. There are five uncontrolled boilers that supply steam to the processes; additionally, boilers
B-1,B-2 and B-3 serve as odor control devices. Boiler B-5 is a temporary boiler that hasn't been on site in
years. The primary control for the intensive rendering emissions is the evaporation of condensables,then
oxidation within the boilers. An alternate scenario is directing non-condensable emissions through the wet
scrubber and cross-flow scrubber,normally used only for room air control. This facility employs—130
workers, including drivers,and operates 24 hours for 5 and one half days each week; the remaining one and
one half days are consumed by maintenance and inspections. The facility opens each control device every
Sunday for cleaning and inspections.
V. INSPECTION SUMMARY: On 29 June 2017 I,Joshua Harris,arrived at Valley Protein to conduct
an air quality compliance inspection. I noted no odors as I drove past the plant, and while on-site,the only
noticeable odors were directly outside the rendering buildings. I met with Chris Bivens, General Manager,
James Hodges,Environmental Manager,and Ryan Kirby, I" Shift Environmental Manager. Mr.Bivens
reviewed the FacFinder data,noted no changes,then we began reviewing the facility's records.
Records at the plant are very well-organized and are kept up-to-date. The plant combusts natural gas
exclusively unless curtailed or for testing,during which saleable fat is combusted. The facility fired fat for
testing for four days 30 October—02 November 2016,and again in January 2017,during a curtailment. The
facility has not accepted any fuel oil in years,and there was none on-site at the time of the inspection. All of
the facility's records appeared complete,and there were no noted concerns. We also had a brief discussion of
the facility's permit renewal application. After reviewing the facility's records,Mr. Hodges,Mr.Kirby, and I
toured the facility.
The facility's boilers were operating on natural gas,with zero opacity noted. All gauge readings (flow rate/
pressure, ORP)were operational and within the permit limits. We discussed the possibility of the facility
using chlorine dioxide again in the future, and Mr. Hodges stated that there are no plans to use it again since
"ActXone"works well,but that the facility would like to keep the chlorine dioxide generators on the permit
for flexibility, even though they have been removed.At the time of the inspection,the longest duration that
any material had been waiting on site was—5 hours. There were no new entries in the facility's"24-hour log"
which is used to record instances in which material is stored on-site for more than 24 hours.

VI. PERMITTED EMISSION SOURCES:
Emission Control
Source Emission Source Description Device Control Device Description
ID No. ID No.
Two natural gas/No.2 fuel oil/No. 6
fuel oil/On Specification recycled No.4
B-1 and equivalent fuel oiVsaleable fat-fired
boilers(33.0 million Btu per hour heat N/A N/A
B-2 input rate each)
Operating rrs odor control device on
natural gas—0% opacity.
One natural gas/No.2 fuel oil/saleable
fat-fired boiler(48.4 million Btu per
B-3 hour heat input) N/A N/A
NSPS Operating as odor control device on
natara[gas—0%opacity.
One natural gas/No.2 fuel oil/No. 6 fuel
oil/On Specification recycled No. 4
equivalent fuel oil/saleable fat-fired
B-4 boiler(33.5 million Btu per hour heat N/A N/A
input)
Operating on natural gas—0%
Opacity.
One natural gas/No.2 fuel oil/No. 6 fuel
oil/On Specification recycled No. 4
equivalent fuel oil/saleable fat-fired
B-5 boiler(29.3 million Btu per hour heat N/A N/A
input)
No longer on site,moved to another
facility
C-5 One air cooled condenser
Feather and Blood Rendering process in series with
consisting of: C-1 One venturi scrubber(minimum scrubber
liquid inlet pressure 9 psig)with a
E2,E3,E4-a, Mist eliminator
E4-b,E4-c, a)Seven bateh cookers
E5-a,E5-b, 11AVE BEEN REDIOVED C-2 venting to One cyclone(60-inch diameter)with a
and E6 either Mist eliminator in series with a
E9 b)One rotary steam tube dryer CY-1 combination of three natural gas/fuel oil
CM-1 /saleable fat-fired boilers
c)One feather hydrolyser B-1 to B-3 or One packed tower scrubber(minimum
C-4 scrubber liquid inlet pressure 3 psig)
d)One feather press
C-3 One venturi scrubber(minimum scrubber
Operating—no abnormalities liquid inlet pressure 5 psig)in series with
E10 C-4 One packed tower scrubber(minimum
noted. scrubber liquid inlet pressure 3 psig)

C-6 One air cooled condenser
El Rendering process consisting of: in series with
One three stage slurry system evaporative C-1 One venturi scrubber(minimum scrubber
condenser cooker with post heater forced liquid inlet pressure 9 psig)with a
circulation chamber on 1"stage Mist eliminator
C-2 venting to One cyclone(60 inch diameter)with a
Operating—no abnormalities noted either Mist eliminator in series with a
CY-1 combination of three(3)natural gas/fuel
CM-1 oil/saleable fat-fired boilers
B-1 to B-3 or One packed tower scrubber(minimum
C-4 scrubber liquid inlet pressure 3 psig)
E18 One fluidizer tank
C-3 One venturi scrubber(minimum scrubber
Operating—no abnormalities noted liquid inlet pressure 5 psig)in series with
C-4 One packed tower scrubber(minimum
scrubber liquid inlet pressure 3 psig)
C 7 One air cooled condenser
in series with
C 1 One venturi scrubber(minimum scrubber
E7 One 320U cooker liquid inlet pressure 9 psig)in series with
C-2 venting to a Mist eliminator
Operating—no abnormalities noted either
CI, 1 One cyclone(60 inch diameter)with a
CM-1 Mist eliminator in series with a
B-1 to B-3 or combination of three natural gas/fuel
C-4 oil/saleable fat-fired boilers
One packed tower scrubber(minimum
scrubber liquid inlet pressure 3 psig)
E8 Press/centrifuge process
One venturi scrubber(minimum scrubber
Operating—no abnormalities noted C 3 liquid inlet pressure 5 psig)in series with
C-4 One packed tower scrubber(minimum
scrubber liquid inlet pressure 3psig)
One,two stage, cross-flow type wet
Plant room air system scrubber,minimum scrubber liquid inlet
E22 Operating—no abnormalities noted C-8 pressure 13 psig with mist eliminator,
utilizing chlorine dioxide or DuPont
ActXone—ZA3001-IS

VH. APPLICABLE AIR QUALITY REGULATIONS:
A. 15A NCAC 2D .0503 PARTICULATES FROM FUEL BURNING INDIRECT HEAT
EXCHANGERS—Emissions of particulate matter from boilers into the atmosphere shall not
exceed 0.367 Ib/mmBtu for boilers B-1 and B-2, 0.318 lb/mmBtu for boiler B-3, 0.30 lb/mmBm
for boiler B-4,and 0.28 Ib/mmBtu for boiler B-5.
APPEARED INCOMPLIANCE—The facility has only combusted natural gas, and some
saleable fat in 2016. The AP-42 emission factor for natural gas is 0.0071b/mmBtu. Source
testing at the facility in April 2001 resulted in a PMemission factor of 0.05 lb/mmBtu while
combusting saleable fat.
B. 15A NCAC 2D.0516 SULFUR DIOXODE EMISSIONS FROM COMBUSTION
SOURCES—Sulfur dioxide emissions from the facility's boilers shall not exceed 2.3 Ib/mmBtu.
The Permittee shall monitor the sulfur content of the No. 6 fuel oil and recycled No. 4 fuel oil by
using fuel oil supplier certifications per shipment received;the sulfur content of the No. 6 is
limited to 2.1 %and the recycled No.4 is 2.0%. Recordkeeping and semiannual reporting.
APPEARED IN COMPLIANCE—The facility fires natural gas exclusively, and will combust
saleble animal fat during testing and curtailment; there is no fuel oil on-site. Some saleable fat
was combusted for testing in the period of 30 October—02 November 2016, and again in
January 2017 during curtailment,for a total of 48,587 gallons over the past 12 months;fuel
analysis records were available. The AP-42 emission factor for natural gas is 0.00061b/mmBtu.
The sulfur content of the fat on-site was determined to be 0.0024 wt.%on 12 January 2017. After
firing fat during curtailment, the storage tanks were refilled and tested again on 24 April 2017.
Results for storage tank#6 indicated a sulfur content of 0.0134%, and for tank#2 0.22691o.
Source testing at the facility in April2001 resulted in an SOz emission factor of 0.0181b/mmBtu
while combusting saleable fat. The semiannual report was recetved on 30 January 2017, and
indicated compliance.
C. 15A NCAC 2D .0521 CONTROL OF VISIBLE EMISSIONS—The visible emissions from the
facility's emission sources shall not be more than 20%opacity. The Permittee shall observe the
visible emissions from the boilers while firing on No. 6 fuel oil,recycled No. 4 fuel oil,No. 2 fuel
oil and animal fat oil,and from the rendering processes daily against"normal." Recordkeeping
and semiannual summary reporting.
APPEARED IN COMPLIANCE—B-1, B-2, B-3, and B-4 were operating on natural gas, with
zero visible emissions during the inspection. There were no visible emissions noted from the
scrubber exhausts. The facility's VE log is well organized and there were no abnormal or excess
emissions noted. The semiannual report was received on 30 January 2017, and indicated
compliance.
D. 15A NCAC 2D .0524 NSPS 40 PART 60 SUBPART Dc—The maximum sulfur content of any
fuel oil combusted in boiler B-3 shall not exceed 0.5%,and the maximum VE shall be 20%. The
Permittee shall record and maintain records of the amounts of No. 2 fuel oil combusted during
each month and of the sulfur content through fuel supplier certifications. Semiannual reporting.
APPEARED IN COMPLIANCE—No fuel oil has been combusted since the last inspection. There is
no fuel oil currently on-site.

E. 15A NCAC 2Q .0317 AVOIDANCE OF PREVENTION OF SIGNIFICANT
DETERIORATION for S02 and CO—Boilers B-1,B-2,B-3 and B-4 shall discharge less than
250 tons of sulfur dioxide and carbon monoxide per consecutive twelve-month period. The
Permittee shall record the amounts of natural gas,No. 2 fuel oil,No. 6 fuel oil, On Specification
No. 4 recycled fuel oil,and animal fat oil combusted in the boilers each month;the Permittee
shall also calculate the amounts of carbon monoxide and sulfur dioxide emitted each month.
APPEARED IN COMPLIANCE—The monthly records are complete, and emissions appear to
be calculated correctly using the emission factors listed in the permit. S02 emissions while firing
natural gas are inconsequential with the monthly emissions averaging—0.015 tons. CO emissions
were consistently around two tons per month and the 12-month rolling total equal to 18.97 tons
as of 31 May 2017.
F. 15A NCAC 2D .0501 EMISSION CONTROL STANDARD—The daily emission of sulfur
dioxide from boilers B-1,B-2,B-3,B-4 and B-5 shall not exceed 3,644.49 pounds per day. The
permit allows calculations based on the PSD avoidance(monthly)calculations,divided by 30.
APPEARED IN COMPLIANCE—The facility makes daily calculations of S02 emissions based
on fuel combusted the previous day. Sulfur content of fuels is so low that average daily S02
emissions are typically less than one pound.
G. 15A NCAC 2D .0515 PARTICULATES FROM MISCELLANEOUS INDUSTRIAL
PROCESSES—Emissions of particulate matter from the feather hydrolyser(ID No. E9),rotary
steam tube dryer(113 No.E6), feather press(ID No. El0),rendering process(ID No. El),and
fluidizer tank(M No. E10),shall be controlled by a series of control devices(venturi scrubbers,
cyclones,and mist eliminators)and shall not exceed those calculated by E=4.10 * P°67,where E
is the allowable emission rate in lb/hr;this is accomplished by properly maintaining the control
devices. The Permittee shall perform a monthly visible inspection, including all ductwork, and an
annual internal inspection of condensers and venturi/packed tower scrubbers.
APPEARED IN COMPLIANCE—During the inspection, all control devices were operating.
Control devices are inspected more frequently than is required, with required inspections
occurring weekly for all control devices with the exception of the facility's condensers which are
inspected internally on a semiannual basis. Problems discovered during each inspection are
noted and corrective actions are taken, though the past year's inspections do not appear to have
turned up any issues.

H. 15A NCAC 2D .0539 ODOR CONTROL FOR FEED INGREDIENT MANUFACTURING
PLANTS—The Permittee shall ensure that odorous emissions are controlled by control devices
as listed in the permit and the Permittee shall install,operate and maintain parameter measuring
and recording devices for these devices. All gases from plant room air,feather and blood
rendering, and rendering process shall pass first through the condensers and then be incinerated at
1200 degrees for 0.3 seconds while the boilers are not in low fire(or treated in an equally
effective manner. All expeller units shall be properly hooded and all exhaust gases directed to
odor control equipment. The Permittee shall take reasonable precautions to prevent odor
discharge during handling,transportation and storage of incoming materials. The Permittee shall
ensure that all odor control devices are inspected, maintained and operated properly; external
inspections monthly, scrubber nozzles cleaned monthly, generation units calibrated monthly, and
a semi-annual internal inspection for all control devices. The Permittee shall ensure the venturi
(C-1)inlet water pressure at a 9 psig minimum,the venturi(C-3)inlet water pressure at a 5 psig
minimum,the packed bed scrubber(C-4) inlet water pressure at a 3 psig minimum,the cross-flow
(C-8)generation unit at a+300 ORP minimum and the scrubber inlet water pressure at a 13 psig
minimum. The Permittee shall monitor the boiler operating parameters once per day for
confirmation of boiler operation above low-fire if being used for odor control. The Permittee
shall record all parameters, inspections and maintenance in a logbook.
APPEARED IN COMPLIANCE— There was a light rendering odor at the street as I entered the
premises, but it dissipated quickly and the only noticeable odor on-site was directly outside the
rendering buildings. During the inspection, I noted operating parameters on the control
equipment as follows: Venturi C-1 (9 psig minimum) was operating at 10 psig, venturi C-3 (5
psig minimum)was operating at 8 psig. The packed tower scrubber C-4 (3 psig minimum) was
operating at 10 psig. The inlets to crossfow scrubber C-8(13 psig minimum) were operating at
22 psig(I"stage) and 24 psig(2nd stage). The ORP values were observed to be +374 in(packed
tower scrubber C4) and+4681+312 mV(stages I and II of cross flow scrubber C8). The
pressures and ORPs are monitored and recorded each shift. All showed compliance, with the
exception of ORP falling low out of specification on 18 April 2017. Mr. Hodges submitted a
notification the next day, DAQ responded on 08 May 2017, stating that the failure of the
controller, leading to the release of excessive malodorous emissions, was considered as a
ma�iinction under 2D.0535(a)(2).
Operator's log for checking high-fire status when the boilers are used for odor control appeared
complete, and logs are taken during each shift. The logs appeared complete and indicated
compliance, though some operators still show a tendency to log the boilers as operating in low-
fire when acting as control devices. Mr. Hodges has sought more information on the issue from
the corporate office, and determined that when the boiler is in `pin position 1,"it is considered
low-fire, and the damper to the boiler is completely closed, meaning all vapor is directed to the
packed tower scrubber. "Pin position 2"and higher is consider mid to high fire, and the damper
to the boiler is fully open while the scrubber damper is completely shut. Mr. Hodges stated that
any instance in which the operators log the boiler as operating as a control device in low-fire is a
recordkeeping error, and is impossible given the way the system is set up. Storage of material
while on-site is tracked electronically, and the longest any material was on-site during the
inspection was—5 hours.
The facility has a rigorous cleaning and inspection regimen, which exceeds the permit
requirement and is completed weekly. Mr. Hodges attributes much of the facility's progress to
this routine, and says he intends to continue with it. Calibrations are completed monthly by
Chemours, and the required 'AaXone"chemical was in use.

I. 15A NCAC 2Q .0317 AVOIDANCE CONDITION FOR 15 A NCAC 2D .I100: CONTROL
OF TOXIC AIR POLLUTANTS—The Permittee shall only combust recycled No. 4 fuel oil that
meets the specifications listed in the permit. The Permittee shall record the amount of recycled
No. 4 delivered to and combusted at the facility and retain the results of analytical testing.
APPEARED IN COMPLIANCE—Zero recycled No. 4 has been purchased or combusted since
2005. There is no recycle oil on-site.
J. GENERAL CONDITION"I"—REPORTING REQUIREMENTS FOR EXCESS
EMISSIONS AND PERMIT DEVIATIONS—The Permittee shall report excess emissions in
accordance with 15A NCAC 21) .0535,and report any permit deviations quarterly.
APPEARED IN COMPLIANCE— Mr. Hodges is aware that the permit requires reports of
excess emissions and of deviations, and submits reports if required. A notification was received
on 19 April 2017, indicating a ma function of an ORP controller which led to ORP being low out
of specification for packed tower scrubber, CD-4,for greater than four hours. DAQ responded
on 08 May 2017, stating that the failure of the controller, leading to the release of excessive
malodorous emissions, was considered as a ma finction under 2D.0535(a)(2).
K. GENERAL CONDITION"P"—COMPLIANCE CERTIFICATION—The Permittee shall
submit a compliance certification annually no later than March 1".
APPEARED IN COMPLIANCE—The facility's ACC was received on 30 January 2017, and
appeared complete and accurate.
L. GENERAL CONDITION"X"—COMPLIANCE CERTIFICATION—The Permittee shall
submit an annual emission inventory for the previous year no later than June 301.
APPEARED IN COMPLIANCE—The facility's CY 2016 AQEI was received on 06 June 2017,
and appeared complete and accurate.
VIII. INSIGNIFICANT ACTIVITIES:
Emission Source I.D. Emission Source Description
IE-21.1,IE-21.2,and One load-out operation consisting of two truck loadout bays in a building open on two
IE-21.3 ends with tractor trailer truck overhead doors,and one railcar loadout open to the
atmosphere.
IE24.1,IE-24.2,and One grinding operation consisting of three(3)hammermill/shaker screen systems in a
IE-24.3 building open on two ends with tractor trailer truck overhead doors
IE-25 Chlorine dioxide generation and delivery system

IX. NON-COMPLIANCE HISTORY SINCE 2010: No non-compliance issues noted.
X. RISK MANAGEMENT(112r): The facility does not store any subject chemical compounds in
quantities that would require a written Risk Management Program(RMP).
XI. CONCLUSIONS AND RECOMMENDATIONS:
Valley Proteins,Inc.—Wadesboro Division appeared to be operating IN COMPLIANCE on 29 June
2017.
PINK SHEET ADDITIONS:
None.
/jlh