AQ_F_0400034_20171026_CMPL_InspRpt (4)

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: 11/01/2017
Facility Data Permit Data
Valley Proteins,Inc.-Wadesboro Division Permit 06467/T18
1 656 Little Duncan Road Issued 10/3/2011
d
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
INAILS: 311613/Rendering and Meat Byproduct Processing Current Permit Application(s)TV-Renewal
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Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP/Title V
Chris Bivans Chris Bivans Robert Vogler
MACT Part 63: Subpart 6J
` NSPS: Subpart Dc
p
General Manager General Manager Director of
[phone] [phone] Environmental Affairs
[phone]
Compliance Data
Comments:
Inspection Date 10/26/2017
Inspector's Name Joshua L.Harris
Inspector's Signature. = � � Operating Status Operating
Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: On-Site Inspection Result Compliance
f Total Actual emissions in TONS/YEAR:
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TSP S02 NOX VOC CO PM10 *HAP
2016 0.2200 0.1800 25.13 17.75 20.71 0.2200 886.68
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
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*Highest HAP Emitted in ounds
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
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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 20
July 2017,but there was some concern due to some cryptic comments and questionable recording of the
procedure by the technician,which did not always show before and after readings for CO. The last full set of j
tune-ups which appeared complete were conducted on 23 January 2017. A copy of the biennial certification
was on-site,and was prepared on time.
H. DIRECTIONS TO SITE: From FRO,take US 401 South through Wagram. South of Wagram,take
Old Wire Road(NC144)to US74. Follow US 74 west through Wadesboro,and turn right(north)onto US52.
Go a few miles,pass Triangle Brick on right, go t/4 mile, and the entrance to the Valley Protein plant is on the f
right. Proceed down the road to the driveway to the office building on the left side of the parking
lot/driveway.
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M. 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. i
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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 j
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 j
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 26 October 2017, Steve Allen,and I,Joshua Harris,both of DAQ
FRO,arrived at Valley Protein to conduct an air quality compliance inspection. We noted slight rendering
odor prior to entering the facility gate, and light odors while on site. We met with Chris Bivens, General
Manager,James Hodges,Environmental Manager,and Ryan Kirby, l't 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. VE
observations during these times indicate that there were no visible emissions. 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,however we did request to see the latest tune-up of the
boilers,which Mr.Bivens needed time to retrieve a copy. We discussed the requirement for quarterly
deviation reports, and the excess emission reporting requirements which had come into question at the sister
facility in Fayetteville. Mr.Hodges is well aware of the requirements, and has been making the reports as
necessary,at the required frequency. We also had a brief discussion of the facility's permit renewal
application,and I explained the process to Mr.Bivens. After reviewing the facility's records,Mr. Hodges,
Mr. Kirby,Mr.Allen 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—10.5 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.
Upon returning to the office building,we were able to review the latest tune-up records. The facility tunes the
boilers semiannually, and the records sent to Mr. Bivens showed the last tune-ups were completed on 20 July
2017. Concerns were noted with cryptic comments made by the technician and also with the fact that before
and after values for CO concentration were not included for each boiler. Mr.Bivens is looking into what
happened, and whether the tune-ups need to be conducted again. The previous tune-ups were conducted on
23 January 2017, and appeared to have been conducted appropriately. Noting no other concerns,we departed
the facility.
VI. PERMITTED EMISSION SOURCES:
Two natural gas/No.2 fuel oil/No.6
fuel oil/On Specification recycled No.4
equivalent fuel oil/saleable fat-fired
B-1 and boilers(33.0 million Btu per hour heat N/A N/A
B-2 input rate each)
Operating as odor control device on
j natural gas—0%opacity.
One natural gas/No.2 fuel oil/saleable
B-3 fat-fired boiler(48.4 million Btu per
NSPS hour heat input) N/A N/A
Operating as odor control device on
natural gas—0% opacity.
1 One natural gas/No.2 fuel oil/No.6 fuel
oil/On Specification recycled No.4
equivalent fuel oil/saleable fat-fired
I B-4 boiler(33.5 million Btu per hour heat N/A N/A
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input)
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Operating on natural gas—0
o pacit v.
One natural gas/No.2 fuel oil/No.6 fuel
oil/On Specification recycled No.4
B-5 equivalent fuel oil/saleable fat-fired
boiler(29.3 million Btu per hour heat N/A N/A
input)
No longer on site;moved to another
acilit,
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C-5 One air cooled condenser
in series with
Feather and Blood Rendering process
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 eeekeFs
E5-a,E5-b, C-2 venting to One cyclone(60-inch diameter)with a
HAVE BEEN REMOVED
and E6 either Mist eliminator in series with a
E9 CY-1 combination of three natural gas/fuel oil 1
b)One rotary steam tube dryer 1
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 noted C-4 One packed tower scrubber(minimum
scrubber liquid inlet pressure 3 psig)
E1 Rendering process consisting of C-6 One air cooled condenser
One three stage slurry system in series with
evaporative condenser cooker with post C-1 One venturi scrubber(minimum scrubber,. __,
heater forced circulation chamber on 1st liquid inlet pressure 9 psig)with a
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
E18 C-4 scrubber liquid inlet pressure 3 psig)
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 3psig)
One air cooled condenser C-7
in series with
C-1 One venturi scrubber(minimum scrubber
E 7 One 320U cooker liquid inlet pressure 9 psig)in series with
C-2 venting to a Mist eliminator
Operating—no abnormalities noted either One cyclone(60 inch diameter)with a
CY-1 Mist eliminator in series with a
CM-1 combination of three natural gas/fuel
B-1 to B-3 or oil/saleable fat-fired boilers
C-4 One packed tower scrubber(minimum r
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)

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One,two stage,cross-flow type wet
Plant room air system scrubber,minimum scrubber liquid inlet
E22 Operating—no abnormalities rioted C-8 pressure 13 psig with mist eliminator,
utilizing chlorine dioxide or DuPont
ActXone—ZA300HS
VII. APPLICABLE AIR QUALITY REGULATIONS:
a 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 lb/mmBtu for boilers B-1 and B-2, 0.3181b/mmBtu for boiler B-3, 0.301b/mm3tu
for boiler B-4, and 0.28 lb/mmBtu for boiler B-5.
APPEARED IN COMPLIANCE—The facility has only combusted natural gas, and some
saleable fat in 2016. The AP-42 emission factor for natural gas is 0.007 lb/mmBtu. Source
testing at the facility in April 2001 resulted in a PM emission 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 lb/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 0.0006 lb/mmBtu.
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- --- 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 0.013491o, and for tank 92 0.226%. We
discussed the sample with Mr. Hodges and Mr. Bivens since it showed a large increase over the
last sample. There doesn't appear to be a concern emission-wise, but Mr. Bivens stated that
they'll be sampling again soon and will watch the next results more closely. Source testing at the
facility in April 2001 resulted in an SOz emission factor of 0.018 lb/mmBtu while combusting
r saleable fat;I requested the suer content of the fat that was used during this test to compare it
to current sample results, but that data has not been able to be located as yet. The semiannual
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report was received on 18 July 2017, and indicated compliance.
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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 1
oil and animal fat oil,and from the rendering processes daily against"normal." Recordkeeping
and semiannual summary reporting. 1
APPEARED IN COMPLIANCE—B-1, B-2, B-3, and B-4 were operating on natural as, with
p g g �
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. We did have a discussion about describing what "normal"emissions are for
the observer, and Mr. Hodges will add a note to the log that the normal for the facility is no
visible emissions. This will apply regardless of the fuel being combusted, since the only fuel 1
other than natural gas is saleable fat, and no visible emissions have ever been noted in the past
while it has been fired in the boilers. The semiannual report was received on 18 July 2017, and !ff
indicated compliance. I
D. 15A NCAC 2D .0524 NSPS 40 PART 60 SUBPART Dc—The maximum sulfur content of any s
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-0.01 S tons. CO emissions
were consistently around two tons per month and the 12-month rolling total equal to 19.1 tons as
of 30 September 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 SO2 emissions based
on fuel combusted the previous day. Sulfur content of fuels is so low that average daily SO2
emissions are typically less than one pound.

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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(ID No. E6), feather press(ID No.E10), rendering process(ID No.E1),and
fluidizer tank(ID 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 0 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.
a Control devices are typically inspected more frequently than is required; internal inspections are
conducted weekly for all control devices during cleaning with the exception of the facility's
condensers which are inspected internally on a semiannual basis. Monthly external inspections
are conducted and recorded as required. No recent issues have been uncovered during
inspections.
H. 15A NCAC 2D .0539 ODOR CONTROL FOR FEED INGREDIENT MANUFACTURING
G 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
t 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
f minimum,the packed bed scrubber(C-4)inlet water pressure at a 3 psig minimum,the cross-flow
(C-9)generation unit at a+300 ORP ininim-urn and the scrubber inlet water pressure at a 13 psig
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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
kpsig minimum)was operating at 10 psig. The packed tower scrubber C-4 (3 psig minimum) was
j operating at 7 psig. The inlets to crossflow scrubber C-8(13 psig minimum) were operating at
[( 22 psig(Is`stage) and 22 psig(2"d stage). The ORP values were observed to be +452 mV(packed
tower scrubber C4) and+10541+454 mV(stages I and II of cross flow scrubber C8). The
pressures and ORPs are monitored and recorded each shift in addition to being continuously
! logged electronically; all showed compliance.
Operator's log for checking high-fire status when the boilers are used for odor control appeared
f complete, and logs are taken during each shift. The logs appeared complete and indicated
compliance, though it is seemingly impossible to operate as a control device in "low-fire." 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"
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and higher is consider mid to high fire, and the damper to the boiler is fully open while the I
scrubber damper is completely shut. While in this state, the scrubber is idle and is in standby in
case vapors need to be directed back away from the boilers. Storage of material while on-site is
tracked electronically, and the longest any material was on-site during the inspection was—10.5
hours.
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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 "ActXone"chemical was in use.
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I. 15A NCAC 2Q .0317 AVOIDANCE CONDITION FOR 15 A NCAC 2D .1100: CONTROL j
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 j
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 malfunction 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 potential release of
excessive malodorous emissions, was considered as a malfunction under 2D.0535(a)(2). The
last quarterly deviation report was received on 10 October 2017, which showed instances of f
malfunctions of the packed tower scrubber, lasting—I hour each due to a failing fan. The fan
was repaired, and eventually replaced.
K. GENERAL CONDITION"P"—COMPLIANCE CERTIFICATION—The Permittee shall
submit a compliance certification annually no later than March 111.
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 30'.
APPEARED IN COMPLIANCE—The facility's CY2016 AQEI was received on 06 June 2017,
and appeared complete and accurate.

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VIII. INSIGNIFICANT ACTIVITIES:
IE-21.1,IE-21.2,and IE- One load-out operation consisting of two truck loadout bays in a building open on two
21.3 ends with tractor trailer truck overhead doors,and one railcar loadout open to the
atmosphere.
IE24.1,IE-24.2,and IE- One grinding operation consisting of three(3)hammermill/shaker screen systems in a
24.3 building open on two ends with tractor trailer truck overhead doors
IE-25 Chlorine dioxide generation and delivery system
REMOVED FROMSITE
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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 with their air
quality permit on 26 October 2017.
PINK SHEET ADDITIONS:
None.
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