AQ_F_0400034_20151202_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY Valley Proteins,Inc. -Wadesboro Division
NC Facility ID 0400034
Inspection Report County/FITS: Anson/007 g
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Date: 12/00015
Facility Data 1 Permit Data
Valley Proteins;Inc. -Wadesboro Division Permit 06467 t Tl8
656 Little Duncan Road Issued 10/3/2011 I
€ Wadesboro,':7C 28170 Expires 913012016
Lat:35d 2.1192m Long: 80d 4.9683m Classification Title V
SIC: 20771 Animal Arid Marine Fats And Oil Permit Status Active
NAICS: 311613/Rendering'and Meat Byproduct Processing Current Permit Application(s)TV-Renewal
Contact Data Program Applicability
I Facility Contact Authorized Contact Technical Contact g gIPI Title V
3 &TACT Part 63: Subpart W
Chris Bivans Chris Bivans I Robert Vogler NSPS: Subpart Dc
General Manager General Manager ; Director of
[phone] [phone] Environmental Affairs
t 1 [phone]
Compliance Data
Comments:
1 Inspection Date 12/02/2015
I Inspector's Name Joshua L. Harris
Inspector's Signature: s_ _-. t Operating Status Operating I
t Compliance Code Compliance-inspection )
I Action Code FCE I
I Date of Signature, r,-,f= On-Site Inspection Result Compliance
€ Total Actual emissions in TONSIYEAR:
TSP S02 NOX VOC CO PMIO HAP i
2014 2.09 0.1700 2738 17.65 22.86 2.09 979.00
2013 1.92 3.40 24.15 13.66 1984. 1.88 844.14
2012 1.87 3.75 23.25 1125 18.99 1.83 808.55
x Highest HAP Emitted(in pounds) I
Five Year Violation history:None
Date Letter Type Rule Violated Violation Resolution Date
1
Performed Stack Tests since last FCE None I
Bate Test Results Test Method(s) Sources)Tested
a
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L MACT/GACT: The facility is subject to GACT 6J,though this is not currently in the permit. The
facility has completed the required energy assessments,and is conducting boiler tune-ups semiannually with
the last tune-up being performed on 06 October 2015.
II. DIRECTIONS 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. 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 130 workers 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.
V. INSPECTION SUMMARY: On 02 December 2015 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 wastewater
lagoons. While on-site,there were light rendering odors close to the buildings,but it seemed to dissipate after
—50 feet. I met with Chris Bivens,General Manager,and James Hodges,Environmental Manager. Mr."
Hodges immediately mentioned that the facility experienced a loss of power to one of its breaker panels
which powers the ORP monitoring and chemical injection system for the crossflow scrubber(fD No.C8). He
stated that the failure occurred around 7 PM the previous day,and that the facility recovered from the power
failure in the hours prior to my arrival. Approximately 12 hours of ORP data was lost for C8. Mr.Hodgesi
stated that he would be drafting a deviation report to submit to FRO. There was a brief discussion about the
changes to the material storage rules within 2D .0539,and, after the inspection,I emailed Mr. Hodges a copy
of the language that is currently being used for permitting. Mr. Hodges reviewed the FacFinder data,noted i
no changes,then we began reviewing the facility's records.
Records at the plant are well-kept,and are readily available. The plant largely burned only NG in 2015,with
some instances of combusting saleable fat, totaling 1,105 gallons through November 2015. The facility;has
not accepted any fuel oil in years,and there was none on-site at the time of the inspection. During the last
compliance inspection it was noted that one operator was improperly logging boilers as being used as control
devices when they are in low-fire. The facility has changed its logs in an attempt to correct this issue,but the
operator is still inconsistent with logging practices. Mr. Hodges explained that it is physically impossible for
the boiler to operate while in low-fire(pin position one). There is an interlock which keeps a damper closed,
preventing vapors from being admitted to the boiler,when the pin is in position one. Once the operator places
the boiler in mid-fire(position two),a solenoid valve admits air to the damper, and it is pneumatically
opened. After reviewing the facility's records, Mr. Hodges and I toured the facility.
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i We first stopped by the wastewater lagoon,where there was no detectible odor. The facility's boilers were
running on NG,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
t on site was 6.5 hours.
VI, PERMITTED EMISSION SOURCES:
emission Control
i Source. Emission Source Description Device Control Device Description
ID No.
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€ Two natural gas/No.2 fuel oil*/No.6 fuel
oil/On Specification recycled No.4
E B-1 and equivalent fuel oil/saleable fat-fired NIA N/A
{ B-2* boilers(33-0 million Btu per hour heat
€ 3 input rate each)
Operating on NG—zero opacity.
F One natural gas/No.2 fuel oiUsaleable fat
3 B-3 -fired boiler(48.4 million Btu per hour
NSPS heat input) N/A N/A
Operating on NG—zero opacity.
One natural gas/No.2 fuel oil No. 6 Mel
oil/On Specification recycled No.4
134 equivalent fuel oil/saleable fat-fired boiler N/A N/A
(33.5 million Btu per hour heat input)
Operating onlN'G—zero o acit
One natural gas/No.2 fuel oil/No-6 fuel
B-5** oil/On Specification recycled No.4
equivalent fuel oiUsaleable fat-fired boiler N/A N/A
(29.3 million Btu per hour heat input)
O eratin on NG—zero o acity
C-5 One air cooled condenser s
t in series with
Feather and Blood Rendering process C-I One venturi scrubber(minimum scrubber
consisting o£ liquid inlet pressure 9 psig)with a t
Ea,E4'b 4 Mist eliminator
E4-c,ES-a, C-2 venting to One cyclone 60 inch diameter)with a
E5-b and HAVEB ED either Mist eliminator in series with a
B9 * CY-I combination of three natural gas/lbel oil
b)One rotary steam tube dryer CM-I /saleable fat-fired boilers
B-I to B-3 or One packed tower scrubber(minimum 1
c)One feather hydrolyser C-4***, **** scrubber liquid inlet pressure 3 psig)
d)One feather press C-3 *** One venturi scrubber(minimum scrubber
liquid inlet pressure 5 psig) in series with
E1Q**** Operating-no abnormalities noted. C-4* *, ** * One packed tower scrubber(minimum
scrubber liquid inlet pressure 3 psig)

C-6 One air cooled condenser
in series with
El Rendering process consisting of: C-1 One venturi scrubber(minimummscrubber
One three stage slurry system evaporative liquid inlet pressure 9 psig)with a
condenser cooker with post heater forced Mist eliminator
circulation chamber on 1st stage C-2 venting to One cyclone(60 inch diameter)with a
either Mist eliminator in series with a
Operating—no abnormalities noted CY-I 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)
C-3**** One venturi scrubber(minimum scrubber
E18 One fluidizer tank liquid inlet pressure 5 psig)in series with
G-4***,**** One packed tower scrubber(minimum
scrubber liquid inlet pressure 3psig)
C 7 One air cooled condenser
in series with
C 1 One venturi scrubber(minimum scrubber
liquid inlet pressure 9 psig)in series with
E7 One 320U cooker
C-2 venting to a Mist eliminator
either One cyclone(60 inch diameter)with a
CY-1 Mist eliminator in series with a
Operating—no abnormalities noted CM-1 B-1 to combination of three natural gas/fuel
,** or oil/saleable fat-fired boilers
One packed tower scrubber(minimum
scrubber liquid inlet pressure 3 psig)
C-3**** One venturi scrubber(minimum scrubber
E8 Press/centrifuge process liquid inlet pressure 5 psig)in series with
C-4***,**** One packed tower scrubber(minimum
scrubber liquid inlet pressure 3 psig)
One,two stage,cross-flow type wet
Plant room air system scrubber,minimum scrubber liquid inlet
LE22 Operating—no abnormalities noted C-8*** pressure 13 psig with mist eliminator,
utilizing chlorine dioxide or DuPont
ActXone—ZA300HS i
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VIL APPLICABLE AIR QUALITY REGULATIONS:
A Taro natural gas/No. 2 fuel oil/No. 6 fuel oil/On Specification recycled No. 4 equivalent fuel
oil/saleable animal fat fined boilers,33 mmBtu each,B-I and B-2, one(1)NSPS natural gas/No.2
fuel oillsaleable animal fat fired boiler,48.4 mmBtu,B-3,one(1)natural gas/No. 2 fuel oil/No. 6 fuel
i oil/On Specification recycled No. 4 equivalent fuel oil/saleable animal fat fired boiler,33.5 mml3tu,
B-4,and one natural gas/No 2 fuel oil/No. 6 fuel oil/On Specification recycled No. 4 equivalent fuel
oil/Saleable fat-fired boiler;29.3 mmBtu, B-5:
1. 15ANCAC 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, 0.318 lb/mmBtu for boiler B-3, 0.30 lb/mml3tu for boiler 13-
4,and 0.28 Ib/mml3W for boiler B-5.
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APPEARED IN COMPLL4NCE—Thefacility has only combusted natural gas, and some saleable
fat in 2015. The AP-42 emission factor for natural gas is 0.007 lb/own3tu. Source testing at the
facilityin April 2001 resulted in a PMeinission factor of 0.05 lb/mmBtu while combusting saleable
s for
2, 15A NCAC 2D .0516 SULFUR DIOXODE EMISSIONS FROM COMBUSTION
SOURCES—Sulfur dioxide emissions 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%. Record keeping and semiannual reporting.
i APPEARED IN COMPLIANCE—All fossil fuel combusted during 2015 was natural gas; there is
no fuel,oil on-site. Some saleable fat was combusted, and fuel analysis records were available. The
AP-42 erni-ssion factor for natural gas is 0.00061b/num6tu The suer content of the fat on-site was
determined to be 35 mglkg(0.0035 wt.%)on 03 September 2015. Source testing at the facility in
April 2001 resulted in an S'02 emission factor of 0.0181b/mmBtu while combusting saleable fat The
semiannual report was received on 20 July 2015.
3. 15A NCAC 2D .0521 CONTROL OF VISIBLE EMISSIONS—The visible emissions from
boilers B-1,B-2,B-3,B-4, and B-5 shall not be more than 20%opacity. The Permittee shall observe
the visible emissions from the boilers firing on No. 6 fuel oil,recycled No. 4 fuel oil,No. 2 fuel oil
and animal fat oil daily against"normal." Record keeping and semiannual summary reporting.
APPEARED IN COMPLL4NCE—B-1, B-2, B-3, B-4, and B-5 were operating on natural gas, with
zero visible emissions during the inspection. The facility's VE log is well organized and there were
no abnormal or excess emissions noted. The semiannual report was received on 20 July 2015, and
indicated compliance with permitted requirements.
4. 15A NCAC 2D .0524 NSPS 40 PART 60 SUBPART Dc—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 IN COMPLIANCE—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 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.S02 emissions while firing
natural gas are inconsequential. CO emissions were consistently below two tons per month with 12
month trolling totals staving around 20 tons.
6. 15A NCAC 2D .0501 EMISSION CONTROL STANDARD—The daily emission of sulfur
dioxide from boilers B-I,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 sulfur content of f rels is so low that monthly S02 emissions
result average daily emissions less than one pound.
B. One feather and blood rendering process consisting of one feather hydrolyser(E9)and seven batch
cookers(E2, E3,E4-a,E4-b, E4-c, ES-a and E5-b)and one rotary steam tube dryer(E6)controlled by
one air cooled condenser(C5) in series with one 50 gpm venturi scrubber(Cl)with a mist eliminator
(0)in series with one 60-inch diameter cyclone(CYI)with a mist eliminator(CMI)in series with
three boilers(B-1,B-2,and B-3)or packed tower scrubber(C4),and one feather press(EI0)
controlled by venturi scrubber(0) in series with packed bed scrubber(C4).
One rendering process consisting of one three stage slurry system evaporative condenser cooker(El)
controlled by one air cooled condenser(C6) in series with one 50 gpm venturi scrubber(Cl)with a
mist eliminator(0)in series with one 60-inch cyclone(CYI) with a mist eliminator(CMI)in series
with three boilers(B-1,B-2, and B-3)or a packed tower scrubber(C-4),
One fluidizer tank(El8)controlled by venturi scrubber(0) in series with packed bed scrubber(C4).
One 320U cooker(0)controlled by one air cooled condenser(C7)in series with one 50 gpm venturi
scrubber(Cl)with a mist eliminator(C2) in series with one 60-inch cyclone(CYI)with a mist
eliminator(CMI) in series with three boilers(B-1, B-2, and 13-3)or a packed tower scrubber(C-4),
and one centrifuge press(E8)controlled by venturi scrubber(0) in series with packed bed scrubber
1. 15A NCAC 2D .0515 PARTICULATES FROM MISCELLANEOUS INDUSTRIAL
PROCESSES—Emissions of particulate matter from these sources shall be controlled by a series of
control devices(venturi scrubbers, cyclones, and mist eliminators)and shall not exceed 4.10 *p osr,
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 condenser
(C5)and venturi scrubber(CI):
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APPEARED IN COMPLIANCE—During the inspection, all control devices were operating.
Control devices are inspected more frequently than is required, with required monthly inspections
occurring weekly, and required annual inspections occurring semiannually. Problems discovered
during each inspection is noted and corrective actions are taken,for example a ductwork inspection
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conducted on 06 September 2015 revealed loose bolts on a flange leading to the condenser, which
were immediately tightened to prevent leakage.
2. 15A NCAC 2D .0521 CONTROL OF VISIBLE EMISSIONS—The visible emissions from
these sources (tiro emission release points—both scrubbers) shall not be more than 20%opacity.
The Permittee shall observe these daily for`normal'VE. Record keeping and semiannual summary
i reporting.
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APPEARED IN COMPLIANCE—During the inspection, I observed no visible emissions from any
of the process equipment or the control devices attached to them. Daily VE(vs 'normal) check is
_ required, and the records appear complete and valid The facility has two certified VE readers on
staff
C, Multiple Emission Sources
1. 15A NCAC 2D .0539 ODOR CONTROL FOR FEED INGREDIENT MANUFACTURING
PLANTS—The Pennittee 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; condensers inspected 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—No odors were detected as I approached the facit ity and only
light rendering odors were noted within about 50 ft of the buildings where rendering operations take
place. During the inspection, I noted operating parameters on the control equipment as follows:
Venturi G-1(9 psig minimum) was operating at 33 psig, venturi C-3 (S psig minimum)was operating
at 9 psig, The packed tower scrubber C-4(3 psig minimum) was operating ai lO psig. The inlets to
crossflow scrubber C-8(13 psig rrrinimurn) were operating at 24 psig(Is'stage)and 28 psig(2"d
stage). The ORP values were observed to be 366 rnV(packed tower scrubber C4) and 3201440 nrV
(stages I and Hof cross flow scrubber C8). the condensers were last serviced on 29 March 2015.
Vallee'Protein has received no odor complaints recently. The pressures are monitored and recorded
each sh f; the ORPs are on continuous strip charts. All showed compliance. Mr. Hodges will be
submitting a deviation report for the 12 hours of lost ORP data for C8 described in the inspection
summary.
Operator's log for checking high-fire status when the boilers an e used fon odor control appeared
complete, and logs are taken during each shift. As previously stated, the facility has changed the
way the logs are taken after the last inspection revealed minor issues. One operator was periodically
taking logs using the old notation, but the logs still indicated compliance.

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.
2. 15A NCAC 2Q .0317 AVOIDANCE CONDITION FOR 15 A NCAC 2D,1100: CONTROL
OF TOXIC AIR POLLUTANTS—The Permittee shall only combust recycled No.4 fuel oil that
meets the specifications listed in the permit. The Pennittee 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,
D. General Condition requirements
1. GENERAL CONDITION"I"—REPORTING REQUIREMENTS FOR EXCESS
EMISSIONS AND PERMIT DEVIATIONS—The Permittee shall report excess emissions in
accordance with 15A NCAC 2D .0535, and report any permit deviations quarterly.
APPEARED INCOMPLIANCE—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 perinit requires reports
of excess emissions and ofdeviations, and will be reporting the missing 1 210 1-1 210 2 ORP data as a
deviation
2. GENERAL CONDITION"P"—COMPLIANCE CERTIFICATION—The Permittee shall
submit a compliance certification annually no later than March Is'
APPEARED INCOMPLIANCE—The facility's ACC was received on 02 Februaq 2015, and
appeared complete and accurate.
1. GENERAL CONDITION"X"—COMIPLIANCE CERTIFICATION—The Permittee shall
submit an annual emission inventory for the previous year no later than June 30`s.
APPEARED IN COMPLIANCE— The facility's CY 2014 AQEI was received on 29 May 2015,and
appeared complete and accurate.
VIII. INSIGNIFICANT ACTIVITIES:
Emission Source 1.8. Emission Source Description
One load-out operation consisting of two truck loadout bays in a in a building open on
t IE-21.I,IE-21.2,and two ends with tractor trailer truck overhead doors,and one railcar loadout open to the
IE-213 atmosphere.
IE24.1,IE-24.2,and One grinding operation consisting of three(3)harnmermill/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 I
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IX. NON-COMPLIANCE HISTORY SINCE 2010: No non-compliance issues noted.
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s X. RISK MANAGEMENT(112r): The facility does not use or store any subject chemical compounds in
l quantities that would require a written Risk Management Program(RMP).
f XI. CONCLUSIONS AND RECOMMENDATIONS:f
Valley Protein—Wadesboro appeared to be operating IN COMPLIANCE on 02 December 2015.
PINK SHEET ADDITIONS: None.
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