AQ_F_0400034_20150115_CMPL_InspRpt

NORTH CAROLINA DIVISION OF _ Fayetteville Regional Office
AIR QUALITY Valley Protein Inc-Wadesboro Div
NC Facility ID 0400034
Inspection Report County/FIPS:Anson/007
Date: 01/16/2015
Facility Data Permit Data
Valley Protein Inc-Wadesboro Div Permit 06467/T18
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
NAICS: 311613/Rendering and Meat Byproduct Processing Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP/Title V
James Hodges Chris Bivans Van Jones MACT Part 63: Subpart 6J
Environmental Manager General Manager Corporate Environmental NSPS: Subpart Dc
[phone] [phone] Manager
[phone]
Compliance Data
Comments:
Inspection Date 01/15/2015
a Inspector's Name Robert Hayden
Inspector's Signature: Operating Status Operating
�/ LLL VV✓111 v Compliance Code Compliance-inspection
, )� Action Code FCE
Date of Signature: J _ On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PMIO *HAP
2013 1.92 3.40 24.15 13.66 19.84 1.88 844.14
2012 1.87 3.75 23.25 13.25 18.99 1.83 808.55
2011 2.07 3.39 23.66 13.27 17.92 2.02 762.68
*Highest HAP Emitted(in ounds)
Five Year Violation History:None
Date Letter Tyne Rule Violated Violation Resolution Date
Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested

NESHAP: The facility is subject to 6J,but the stipulation is not yet in the permit. Even so,the facility is
taking appropriate continuous compliance measures, and has completed the necessary energy assessments,
and tune-ups for the four boilers on site.
I. 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 %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.
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.
IL 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. Business is currently good. Variations at this plant are due more to internal management than
market forces. Some VP plants are more efficient at processing different feed stock. The last inspection was
conducted by Robert Hayden, and Bishop Odom(intern)on 05 June 2014.
III. INSPECTION SUIVIMARY: On 15 January 2015 I,Robert Hayden, along with Heather Carter and
Joshua Harris, arrived at Valley Protein to conduct an air quality compliance inspection. The wind was calm
as we drove past the wastewater lagoon, and no odors were detected. We met with General Manager, Mr.
Chris Bivans, and also with Mr.James Hodges,Environmental Manager. The plant has burned only NG
since the last inspection,with the exception of two instances, on 07 January and 12 December 2014,when an
attempt to burn animal fat was made. During those attempts,the thermal output was determined to be
insufficient, so the attempts were abandoned after burning 700 lbs of animal fat. During a review of the
facility's records,Heather noted that one of the plant's operators had been logging the boilers as odor control
devices when they were, in fact, not being used as control devices during that time. There seemed to be some
confusion as to how to determine when the boiler is high fire or low fire. Both Mr. Bivens, and Mr. Hodges
agreed that they should, and will, conduct training with their operators on this topic. We discussed the
upcoming report that is due 30 January 2015, and Mr.Hodges is currently generating the report. We then
toured the plant, checked gauge readings, and inspected all emission points.
We first stopped by the wastewater lagoon,where there was no detectible odor. Mr. Hodges would later tell
us that the lagoon's capacity had been increased to allow for a longer residence time,which seems to have
been effective. We moved on to see that four boilers were running on NG,with zero opacity. All gauge
readings(flow rate/pressure, ORP)were operational and within the permit limits. I,again, suggested they
stencil the permit ID numbers beside the gauges,just in case a future guide was unfamiliar with which
controls were which. We discussed raw material storage, and plant personnel said that it never happens. At

the time of the inspection,the longest that any material had been waiting on site was 11 hours,which was
already automatically flagged by their system as approaching the 24 hour time limitation.
IV. PERMITTED EMISSION SOURCES:
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Two natural gas/No.2 fuel oil*/No. 6 fuel
oiU On Specification recycled No.4
B-1 and equivalent fuel oil/saleable fat-fired N/A N/A
B-2* boilers(33.0 million Btu per hour heat
input rate each)
Operating on NG—zero opacity.
One natural gas/No.2 fuel oil/saleable fat
B-3 -fired boiler(48.4 million Btu per hour N/A N/A
NSPS heat input)
Operating on NG—zero opacity.
One natural gas/No.2 fuel oil/No.6 fuel
oiVOn Specification recycled No.4
B-4 equivalent fuel oil/saleable fat-fired boiler N/A N/A
(33.5 million Btu per hour heat input)
Operating on NG—zero opacity
One natural gas/No.2 fuel oil/No.6 fuel
B 5** oil/On Specification recycled No.4
equivalent fuel oil/saleable fat-fired boiler N/A N/A
(29.3 million Btu per hour heat input)
Operating on NG—zero opacity
C-5 One air cooled condenser
in series with
Feather and Blood Rendering process C-1 One venturi scrubber(minimum scrubber
E2,E3,E4- consisting of: liquid inlet pressure 9 psig)with a
a,E4-b, Mist eliminator
E4-c,E5-a
E5-b,and a)Seven batch cookers C-2 venting to One cyclone ina inch diameter)with a
either Mist eliminator in series with a
E6
E E6** b)One rotary steam tube dryer CY-1 combination of three natural gas/fuel oil
CM-1 /saleable fat-fired boilers
c One feather h drol ser B-1 to B-3 or One packed tower scrubber(minimum
Y y C-4***, **** scrubber liquid inlet pressure 3 psig)
d)One feather press C-3**** One venturi scrubber(minimum scrubber
Operating—no abnormalities noted. **** liquid inlet pressure 5 psig)in series with
E10**** C-4*** One packed tower scrubber(minimum
scrubber liquid inlet pressure 3 psig)
El Rendering process consisting of: C-6 One air cooled condenser
One three stage slurry system evaporative in series with
condenser cooker with post heater forced C-1 One venturi scrubber(minimum scrubber
circulation chamber on Ill stage liquid inlet pressure 9 psig)with a
Mist eliminator
Operating—no abnormalities noted C-2 venting to One cyclone(60 inch diameter)with a

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 One fluidizer tank C-4*** **** scrubber liquid inlet pressure 3 psig)
C-3**** One venturi scrubber(minimum scrubber
liquid inlet pressure 5 psig)in series with
C-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 combination of three natural gas/fuel
B-1 to B-3 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
E22 Operating—no abnormalities noted C-8*** pressure 13 psig with mist eliminator,
utilizing chlorine dioxide or DuPont
AcLKone—ZA300HS
V. APPLICABLE AIR QUALITY REGULATIONS:
A. Two natural gas/No. 2 fuel oil/No. 6 fuel oil/On Specification recycled No. 4 equivalent fuel
oil/saleable animal fat fired boilers, 33 mmBtu each,B-1 and B-2, one(1)NSPS natural gas/No.2
fuel oil/saleable animal fat fired boiler, 48.4 mmBtu,B-3, one(1)natural gas/No. 2 fuel oil/No. 6 fuel
oil/On Specification recycled No.4 equivalent fuel oil/saleable animal fat fired boiler,33.5 mmBtu,
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. 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 lbs/ mtBtu for boilers B-1 and B-2, 0.318 lbs/mmBtu for boiler B-3, 0.30 lbs/mmBtu for boiler
B-4, and 0.28 lbs/mmBtu for boiler B-5.
APPEARED IN COMPLIANCE—The highest AP-42 emission factor for the permitted fuels is 0.16
lbs/mmBtu;natural gas is 0.007 lbs/mmBtu for No. 6 and No. 4 fuel oil; animal fat oil is 0.05
Ibs/mmBtu. With the exception of 07 January, and 12 December 2014, the facility has combusted
solely NG since the last inspection.

2. 15A NCAC 2D .0516 SULFUR DIOXODE EMISSIONS FROM COMBUSTION
SOURCES—Sulfur dioxide emissions shall not exceed 2.3 lbs/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.
APPEARED INCOMPLIANCE—All fossil fuel combustion since last inspection was NG.
3. 15A NCAC 2D .0521 CONTROL OF VISIBLE EMISSIONS—The visible emissions from
boilers B-1,B-2,B-3 and B-4 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 COMPLIANCE—B-1, B-2, B-3 and B4 were operating on natural gas, with zero
visible emissions. There were no abnormal readings recorded. While firing NG,facility checks VE
daily. On 07 January 2014 animal fat was burned in B-1, B-2, and B-4, and again on 12 December
2014 in B-4, with no abnormalities noted. VE log is well organized and showed no exceedances. The
semiannual report was received on 21 July 2014, 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 oil has been combusted since the last inspection.
5. 15A NCAC 2Q.0317 AVOIDANCE OF PREVENTION OF SIGNIFICANT
DETERIORATION for SO2 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. SO2 emission under NG are
inconsequential. CO emissions were consistently below two tons per month with 12 month rolling
totals staying around 20 tons.
6. 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 COMPLLANCE—NG combustion generates SO2 levels generally less than 1
lb/day.
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,E5-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
(C2)in series with one 60-inch diameter cyclone(CYl)with a mist eliminator(CM1)in series with
three boilers(B-1,B-2, and B-3)or packed tower scrubber(C4),and one feather press(E10)
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(C1)with a
mist eliminator(C2)in series with one 60-inch cyclone (CYl)with a mist eliminator(CMl)in series
with three boilers(B-1, B-2, and B-3)or a packed tower scrubber(C-4),
One fluidizer tank(E18)controlled by venturi scrubber(0)in series with packed bed scrubber(C4).
One 320U cooker(M) 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(CMl) in series with three boilers(B-1,B-2, and B-3)or a packed tower scrubber(C-4),
and one centrifuge press (E8) controlled by venturi scrubber(0)in series with packed bed scrubber
(C4).
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 aez
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).
APPEARED INCOMPLIANCE—During the inspection, all control devices were operating. I
reviewed the I&Mrecords of the control devices and found that the Permittee appears to perform the
required monthly inspections weekly. Each inspection worksheet is tailored to the control device.
2. 15A NCAC 2D .0521 CONTROL OF VISIBLE EMISSIONS—The visible emissions from
these sources (two 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
reporting.
APPEARED IN COMPLLgNCE—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 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; 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 high 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 we approached the facility. During
the inspection, I noted operating parameters on the control equipment as follows: Venturi CI (9 psig
minimum) was operating at 15 psig, venturi C3 (5 psig minimum)was operating at 9 psig. The
packed tower scrubber (C4) (3 psig minimum) was operating at 3 psig, and the inlets to crossflow
scrubber C8 (13 psig minimum) were operating at 20 psig and 20 psig. ORP values were observed to
be 356 mV(packed tower scrubber) and 3081399 mV(stages I and II of cross flow scrubber). The
condensers were last serviced on 23 Apr 14. Valley Protein has received no odor complaints recently.
The pressures are monitored and recorded each shift; the ORPs are on continuous strip charts. All
showed compliance.
The permit requires an operator's log for checking high fire status when the boilers are used for odor
control. The facility records `pin"location, which is the vane/damper indicating firing rate. Pin
locations above 3 indicate high fire. As previously stated, one operator seemed to be confused as to
when the boiler was operating as a control device, but Mr. Bivens, and Mr. Hodges will hold a
training session with their operators to correct this issue.
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 (State Only Requirement)—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 COMPLMNCE—Zero recycled No. 4 has been purchased or combusted since 2005.
The need for a negative report was emphasized.
VI. CHEMICAL ACCIDENT PREVENTION/Sec 112r: The facility does not use or store any subject
chemical compounds in a quantity that would require a written Risk Management Program.
VH. PERMIT EXEMPT EMISSION SOURCES:
A. One loadout operation, IE21.1, IE21.2, and IE21.3, consisting of two bays in a building open on two
ends and one railcar loadout,
B. One grinding operation IE24.1,IE24.2, and IE24.2, consisting of three hammermill/shaker screen
systems.
VH. FIVE YEAR COMPLIANCE HISTORY: No adverse compliance actions in last 5 years.
VHL CONCLUSIONS AND RECOMMENDATIONS:
A. At the time of the inspection,Valley Protein appeared to be operating in compliance with all air
permit stipulations.
B. Next inspection should include a check to ensure operator training was held, as discussed,with
regard to boilers being operated as control devices.This should also be reflected in the logs taken
by the operators, showing appropriate entries that correlate to boiler firing rates.
C. PINK SHEET ADDITIONS: None required.