AQ_F_0400034_20120314_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: 03/14/2012
Facility Data Compliance Data
Valley Protein Inc-Wadesboro Div Inspection Date 03/14/2012
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 Signature:/\ a , 3<, ,'_ n Comments:
Date of Signature: /�_)'^—
NESHAP:
(1) 6J: 5 boilers would be subject, but has adopted the DAQ exemption for operating solely under natural gas
other than for curtailment, emergency and I&M.
(2)4Z: Mr Hodges reiterated what Mr Diebert said in 2011: the facility has no emergency generators or fire
pumps.
There are no apparently applicable NESHAPs.
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/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.
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.
III. INSPECTION SUMMARY: On 13 March 2012, I,Robert Hayden, arrived at Valley Protein to
conduct the annual compliance inspection. The wind was light and changing. I did not note any odor as we
approached. I met with James Hodges, Environmental Manager. We reviewed the records of observations,
production, fuel usage, CO and S02 emissions, and control device inspection and maintenance. The plant has
burned no oil since the last inspection,reducing the monitoring and record keeping. We then toured the plant,
checked gauge readings and all emission points.
The facility is considering changing from the DuPont scrubber solution back to chlorine dioxide, because of
cost and issues with the supplier. As usual, the only significant odor noted was just downwind from the
wastewater tank. There was some odor noted on the roof, apparently escaping from the cooking area through
seals on the access doors. Mr Hodges will track it down and correct.
IV. PERMITTED EMISSION SOURCES:
Emission Control
Source Emission Source Description Device Control Device Description
ID No. ID No.-
Two natural gas/No. 2 fuel oil*/No. 6 fuel
B-1 and oil/On Specification recycled No.4
B 2* equivalent fuel oil/saleable fat-fired N/A N/A
boilers(33.0 million Btu per hour heat
input rate each)
B 3 One natural gas/No. 2 fuel oil/saleable fat
NSPS -fired boiler(48.4 million Btu per hour N/A N/A
heat input)
One natural gas/No.2 fuel oil/No. 6 fuel
B-4 oil/On Specification recycled No.4 N/A N/A
equivalent fuel oil/saleable fat-fired boiler
(33.5 million Btu per hour heat input)
One natural gas/No.2 fuel oil/No.6 fuel
B-5** oil/On Specification recycled No.4 N/A N/A
equivalent fuel oil/saleable fat-fired boiler
(29.3 million Btu per hour heat input)
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 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 13-1 to 13-3 or One packed tower scrubber(minimum
C-4***, **** scrubber liquid inlet pressure 3 psig)
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
C-1 One venturi scrubber(minimum scrubber
El Rendering process consisting of:
liquid
One three stage slurry system evaporative uid inlet pressure 9 psig)with a
Mist eliminator
condenser cooker with post heater forced
circulation chamber on I"stage 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
C-4*** **** scrubber liquid inlet pressure 3 psig)
E18 One fluidizer tank 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 3 psig)
One air cooled condenser C
in series with
C-1 One venturi scrubber(minimum scrubber
liquid inlet pressure 9 psig)in series with
C-2 venting to a Mist eliminator
E7 One 320U cooker either
CY-1 One cyclone(60 inch diameter) with a
CM-1 Mist eliminator in series with a
1 to 3 or combination of three natural gas/fuel
B- to B-
C- B-*** 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
scrubber, minimum scrubber liquid inlet
E22 Plant room air system C-8*** pressure 13 psig with mist eliminator,
utilizing chlorine dioxide or DuPont
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, 13-1 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 1bs/mmBtu for boiler B-3, 0.301bs/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 Ibs/mmBtu; natural gas is 0.007 Ibs/mmBtu for No. 6 and No. 4 fuel oil; animal fat oil is 0.05
lbs/mmBtu. The facility has not burned fuel oil (as fuel) for over a year.There was a NG curtailment
the week prior, and the facility switched to combusting fat, which requires the addition of a small
quantity of fuel oil to denature.
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 facility has not burned fuel oil for over a year(other than as
a denaturing agent for the liquid fat-fuel). The most recent oil supplier certification (I I Dec 10)
showed sulfur content of No. 6 fuel at 2.1%. The facility does not store#6, but orders as needed
during NG curtailment, which occurred the week prior to the inspection). The last report was
received on time(30 Jan 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 no oil has been combusted in over a year, the facility checks VE daily; VE
log is well organized and showed no exceedences. The last report was received on time (30 Jan), 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—No oil has been combusted for over a year. The fuel records are
well organized. The last report was received on time (30 Jan), was complete and appeared legitimate.
5. 15A NCAC 2D .0530 PREVENTION OF SIGNIFICANT DETERIORATION—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. SO2 emission under NG are inconsequential. The last report was
received on time (30 Jan), was complete and appeared legitimate.

The tracking and reporting system is overly large and convoluted. I promised to send Mr Hodges a
smaller, more convenient and efficient model.
6. 15A NCAC 2D .0501 EMISSION CONTROL STANDARD—The daily emission of sulfur
dioxide from boilers B-1,13-2, 13-3, 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. .
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(CM I) in series with
three boilers (B-1, B-2, and 13-3) 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(Cl)with a
mist eliminator(C2) in series with one 60-inch cyclone(CYI) 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(CYI) with a mist
eliminator(CM1) in series with three boilers (13-1, 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
(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 067;
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 Jan),
was complete and appeared legitimate.
2. 15A NCAC 2D .0521 CONTROL OF VISIBLE EMISSIONS—The visible emissions from
these sources 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)is required
only when combusting fuel oil, but the facility checks all stacks daily regardless of fuel, and logs
results. The last report was received on time(30 Jan), 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

i
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. 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 C1
(9 psig minimum) was operating at 12 psig, venturi C3 (5 psig minimum)was operating at 13 psig.
The packed tower scrubber Q 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 II 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.
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 No. 4 has been purchased or combusted since 2005. The
last report was received on time (30 Jan 12), was complete and appeared legitimate.
VI. CHEMICAL ACCIDENT PREVENTION/See 112r: The facility does not use or store any subject
chemical compounds in a quantity that would require a written Risk Management Program.
VIL PERMIT EXEMPT EMISSION SOURCES:
A. One loadout operation, 1E21.1, 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.
VII. COMPLIANCE HISTORY: In September 2002, FRO issued an NOV/NRE for offensive off-site
odor and failure to record scrubber pH and flow rate; FRO rescinded the NRE in November 2002. In March
2002, FRO issued an NOV for late reporting.
VIII. CONCLUSIONS AND RECOMMENDATIONS: At the time of the inspection, Valley Protein
appeared to be operatine in compliance with all air permit stipulations.