AQ_F_0400034_20161117_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: 12/05/2016
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 [NSPS:
/Title VLT Part
Chris Bivans Chris Bivans Robert Vogler rt Subpart 6J
General Manager General Manager Director of Subpart Dc
[phone] [phone] Environmental Affairs
[phone]
Compliance Data
Comments:
Inspection Date 11/17/2016
Inspector's Name Joshua L.Harris
Inspector's Signature: Operating Status Operating
Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: iz/as/i-a, a On-Site Inspection Result Compliance
Total Actual emissions in TONSIYEAR:
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 15
May 2016. A copy of the biennial certification was on-site.
H. DIRECTIONS TO SITE: From FRO,take US 401 South through Wagram. South of Wagram,take
3 Old Wire Road(NC 144)to US74. Follow US 74 west through Wadesboro, and turn right(north)onto US52.
3 Go a few miles, pass Triangle Brick on right,go '/4 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.
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.
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. One is permitted as an emergency boiler. 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 115 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 17 November 2016 I, Joshua Harris, arrived at Valley Protein to
conduct an air quality compliance inspection. I noted faint rendering odors as I drove past the plant,and no
odors near the wastewater lagoons. While on-site,the only noticeable odors were directly outside the
rendering buildings. I met with Chris Bivens,General Manager, and James Hodges, Environmental Manager.
Mr.Hodges 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 only combusted natural gas in
2016,with the exception of four days 30 October—02 November, saleable fat was fired for testing. 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 and I toured the
facility.
The facility's boilers were operating on natural gas,with zero opacity. All gauge readings(flow rate/
pressure, ORP)were operational and within the permit limits. At the time of the inspection,the longest
duration that any material had been waiting on site was—10 hours. There were 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.
However, it appeared that material was either processed or sent to the landfill(in cases where deadstock was
left),before the 24-hour threshold. Mr. Hodges stated that sometimes operators will make log entries if they
think there is a chance that the time limit may be exceeded. I reminded Mr. Hodges that NC has changed the
storage times in 2D .0539,and that those new times may be in the next permit revision when issued.

VI. PERMITTED EMISSION SOURCES:
w
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 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 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-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 ba4eh eeekers
E5-a,E5-b, HAVE BEEN REMOVED 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 s'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)
E 18 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
in series with
One Venturi scrubber(minimum scrubber
E7 One 320U cooker C 1 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
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—ZA300HS

VH. APPLICABLE AIR QUALITY REGULATIONS:
1. 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 1b/mmBtu for boilers B-1 and B-2, 0.318 lb/mmBtu for boiler B-3, 0.30 lb/mmBtu for boiler B-
4, and 0.281b/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 Apri12001 resulted in a PMemission factor of 0.05 lb/mmBtu while combusting saleable
fat.
2. 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 in the period of 30 October—02 November 2016, and fuel analysis records were
available. The AP-42 emission factor for natural gas is 0.0006 lb/mmBtu. The suer content of the
fat on-site was determined to be 0.0065 wt.%on 08 November 2016. Source testing at the facility in
April 2001 resulted in an S02 emission factor of 0.018 lb/mmBtu while combusting saleable fat. The
semiannual report was received on 19 July 2016, and indicated compliance.
3. 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 19 July 2016, and indicated compliance.
4. 15A NCAC 2D.0524 NSPS 40 PART 60 SUBPART De—The maximum sulfur content of any
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 INCOMPLL4NCE—No fuel oil has been combusted since the last inspection. There is no
fuel oil currently on-site.

5. 15A NCAC 2Q.0317 AVOIDANCE OF PREVENTION OF SIGNIFICANT
DETERIORATION for S02 and CO—Boilers B-1,B-2,B 3 and BA 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 21.6 tons as of 30
September 2016
6. 15A NCAC 2D .0501 EMISSION CONTROL STANDARD—The daily emission of sulfur
dioxide from boilers B-1, B-2,B-3,BA 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 COMPLI4NCE—The su fur content offuels is so low that monthly S02 emissions
result average daily emissions less than one pound.
7. 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. El), 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.
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 is noted and
_ corrective actions are taken, though the past year's inspections do not appear to have turned up any
issues.

8. 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 18 psig, venturi C-3 (5 psig minimum)
was operating at 10 psig. The packed tower scrubber C-4 (3 psig minimum) was operating at 10
psig. The inlets to crossflow scrubber C-8(13 psig minimum) were operating at 22 psig(]'stage)
and 26 psig(2nd stage). The ORP values were observed to be 447 mV(packed tower scrubber C4)
and 3661439 mV(stages I and II of cross flow scrubber C8). The pressures are monitored and
recorded each shift, the ORPs are on continuous strip charts. All showed compliance.
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. Storage of material while on-site is tracked electronically, and the longest any material
was on-site during the inspection was—10 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 `ActXone"chemical was in use.
9. 15A NCAC 2Q.0317 AVOIDANCE CONDITION FOR 15 A NCAC 2D .1100: CONTROL
OF TOXIC AIR POLLUTANTS—The Pennittee 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 INCOMPLIANCE—Zero recycled No. 4 has been purchased or combusted since 2005.
There is no recycle oil on-site.

10. GENERAL CONDITION"I"—REPORTING REQUIREMENTS FOR EXCESS
j EMISSIONS AND PERMIT DEVIATIONS—The Permittee shall report excess emissions in
accordance with 15A NCAC 2D .0535, and report any permit deviations quarterly.
APPEARED IN COMPLIANCE—There are no indications of excess emissions,'nor have there been
any complaints made to the facility or to DAQ. Mr. Hodges is aware that the permit requires reports
of excess emissions and of deviations.
11. GENERAL CONDITION"P"—COMPLIANCE CERTIFICATION—The Permittee shall
submit a compliance certification annually no later than March 11
APPEARED IN COMPLIANCE—The facility's ACC was received on 13 January 2016, and
appeared complete and accurate.
12. 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 CY 2015 AQEI was received on 09 June 2016, and
appeared complete and accurate.
VUL INSIGNIFICANT ACTIVITIES:
IE-21.1,1E-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 I building open on two ends with tractor trailer truck overhead doors
IE-25 Chlorine dioxide generation and delivery system
IX. NON-COMPLL4,NCE 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 17
November 2016.
PINK SHEET ADDITIONS: None.
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