AQ_F_0400034_20130129_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: 01/31/2013
Facility Data Compliance Data
Valley Protein Inc-Wadesboro Div Inspection Date 01/29/2013
Little Duncan Road Inspector's Name Robert Hayden
Wadesboro,NC 28170 Operating Status Operating
Lat: 35d 2.1192m Long: 80d 4.9683m Compliance Code Compliance-inspection
SIC: 2077/Animal And Marine Fats And Oil Action Code FCE
NAICS: 311613/Rendering and Meat Byproduct Processing On-Site Inspection Result Compliance
Contact Data Permit Data
Facility Contact Authorized Contact Technical Contact Permit 06467/T18
Dean Deibert Dean Deibert Van Jones Issued 10/3/2011
General Manager General Manager Environmental Manager Expires 9/30/2016
[phone] [phone] [phone] Classification Title V
Permit Status Active
Inspector's Signat � Comments:
Date of Signature:
NESHAP:
(1) 6J: 5 boilers are subject. The NOCS was received after the first tune-up. There is no IN in the file,but a
copy will be requested from the facility ASAP.
(2) 4Z: The facility has no emergency generators or fire pumps. The fire suppression system is powered by
city water pressure only.
I. DIRECTIONS TO SITE: From FRO,take US401 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 1/4 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.
II. FACILITY DESCRIPTION: The facility renders chicken feathers, blood,fat and organs for a
number of processors. 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 condensibles,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.
M. INSPECTION SUMMARY: On 29 January 2013,Heather Hawkins,Mike Thomas and I,Robert
Hayden,arrived at Valley Protein to conduct an air quality compliance inspection. The wind was light and
changing. We did not note any odor as we approached. We met initially with Mr. Diebert, and also with Mr.
David Locklear,Maintenance Manager and Chester Rogers,the wastewater Supervisor-in-training. Mr.
Hodges was at HAZWOPR training,but joined us later. We split up,with Ms Hawkins checking records with
Mr.Diebert(and Hodges later)and Mr Thomas and I did a plant tour with Mr.Locklear. The plant has
burned only NG since the last inspection, except for 22,000 gallons of No. 6 oil in November. We then
toured the plant,checked gauge readings and all emission points.
We checked all monitoring gauges and all emission points for opacity. Three boilers were running on NG,
with zero opacity. All gauge readings (flow rate/pressure, ORP)were compliant. One gauge on the cross-
flow scrubber was inoperative,and immediately put on work order. There was medium-strength rendering
odor in several locations,but none detected offsite. I checked the load-out area. Mr Locklear said there had
been no railcar loading in years. The was a truck being loaded with protein meal,with virtually zero dust
outside the enclosure(roof, 3 walls,uncontrolled).
IV. PERMITTED EMISSION SOURCES:
Two natural gas/No.2 fuel oil*/No.6 fuel
oil/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
NSPS heat input) N/A N/A
Operating on NG—zero opacity.
One natural gas/No.2 fuel oil/No.6 fuel
oil/On 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)
Not operating
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)
Not operating
Feather and Blood Rendering process C-5 One air cooled condenser
consisting of in series with
E2,E3,E4- C-1 One venturi scrubber(minimum scrubber
a,E4-b, liquid inlet pressure 9 si )with a

a,E4-b, liquid inlet pressure 9 psig)with a
E4-c,E5-a, a)Seven batch cookers Mist eliminator
E5-b,and
E6 b)One rotary steam tube dryer C-2 venting to One cyclone(60 inch diameter)with a
E9**** either Mist eliminator in series with a
c)One feather hydrolyser CY-1 combination of three natural gas/fuel oil
CM-1 /saleable fat-fired boilers
d)One feather press B-1 to B-3 or One packed tower scrubber(minimum
C-4***, **** scrubber liquid inlet pressure 3 psig)
Operating—no abnormalities noted.
C-3**** One venturi scrubber(minimum scrubber
E10**** liquid inlet pressure 5 psig)in series with
C-4***, **** One packed tower scrubber(minimum
scrubber liquid inlet pressure 3 psig)
C-6 One air cooled condenser
in series with
E1 Rendering process consisting of. C-1 One venturi scrubber(minimum scrubber
One three stage slurry system evaporative liquid inlet pressure 9 psig)with a
condenser cooker with post heater forced Mist eliminator
circulation chamber on ls`stage C-2 venting to One cyclone(60 inch diameter)with a
either Mist eliminator in series with a
Operating—no abnormalities noted 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)
C-3**** One venturi scrubber(minimum scrubber
E18 One fluidizer tank 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
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
13-1 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 3psig)
Plant room air system One,two stage,cross-flow type wet
Operating—no abnormalities noted, *** scrubber,minimum scrubber liquid inlet
E22 C-8 pressure 13 psig with mist eliminator,
except one zone's pressure gauge was utilizing chlorine dioxide or DuPont
inoperative. ActXone—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/mmBtu for boilers B-1 and B-2, 0.318 lbs/mmBtu for boiler B-3, 0.30 lbs/mmBtu for boiler
B-4,and 0.281bs/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 0.0071bs/mmBtu for No. 6 and No. 4 fuel oil; animal fat oil is 0.05
lbs/mmBtu. The facility burned about 22,000 gallons of No. 6 in November, and NG the rest of the
time 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 IN COMPLIANCE—The certification for the No. 6 combusted in November was on
file and indicated 2.1% sulfur. All other combustion in 2012 was NG. The last report was received
on time(30 Jul 12),was complete and appeared legitimate.
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. While on No. 6 oil in November, daily VE checks were recorded. There were no
abnormal readings recorded. While ffing NG, facility checks VE daily anyway;VE log is well
organized and showed no exceedences. The last report was received on time(30 Jul 12),was
complete and appeared legitimate.
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 IN COMPLIANCE—Oil was combusted in November,but only in boilers B-1 and B-4
(non-NSPS). The fuel records are well organized. The last report was received on time(30 Jul), was
complete and appeared legitimate.
5. 15A NCAC 2D .0530 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 the format is improved
and more readable than prior. S02 emission under NG are inconsequential. The last report was
received on time(30 Jul 12),was complete and appeared legitimate.
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 COMPLIANCE—NG combustion generates S02 levels generally less than 1
lb/day. The daily average in November when the No. 6 was combusted was 2421bs.
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(CY1)with a mist eliminator(CMI)in series with
three boilers(13-1,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(E1)
controlled by one air cooled condenser(C6) in series with one 50 gpm venturi scrubber(C 1)with a
mist eliminator(C2)in series with one 60-inch cyclone(CY1)with a mist eliminator(CM1) 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(E7)controlled by one air cooled condenser(C7)in series with one 50 gpm venturi
scrubber(C1)with a mist eliminator(C2)in series with one 60-inch cyclone(CY1)with a mist
eliminator(CM I) 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 0,67;
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(C1).
APPEARED IN COMPLIANCE—During the inspection,all control devices were operating except
the venturi that broke during the inspection. I reviewed the I&M records 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. The last report was received on time(30 Jul
12),was complete and appeared legitimate.
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 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 Records appear complete and valid. The last report was received on time(30 Jul 12),was
complete and appeared legitimate.

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—I detected no rendering odor as i approached the facility.
During the inspection,I noted operating parameters on the control equipment as follows: Venturi C 1
(9 psig minimum)was operating at 12 psig,venturi C3 (5 psig minimum)was operating at 13 psig.
The packed tower scrubber(3 psig minimum)was operating at 10 psig,and the inlets to crossflow
scrubber C8(13 psig minimum)were operating at 18 psig and 21 psig. ORP values were observed to
be 351 mV(packed tower scrubber)and 353/482 mV(stages I and 11 of cross-flow scrubber). The
condensers were last serviced on 9 Oct 11,and are scheduled for the next for 18 mar 12. 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 last report was received
on time(30 Jan 12),was complete and appeared legitimate.
One area needing improvement was the operator's log for checking high fire status when the boilers
are used for odor control. An edited log format was given to Mr.Hodges,who said he would
incorporate it immediately.
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 COMPLIANCE—Zero recycled No. 4 has been purchased or combusted since
2005. The last report was received on time(30 Jul 12),was complete and appeared legitimate.
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.
VII. 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 EE24.2, consisting of three hammermill/shaker screen
systems.

VII. FIVE YEAR COMPLIANCE HISTORY: No adverse compliance actions in last 5 years.
VIH. 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 evaluating pending compliance with NESHAP 6J plus a check of
any parked raw material trailers parked onsite.