AQ_F_0400034_20110118_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: 01/19/2011
Facility Data Compliance Data
Valley Protein Inc-Wadesboro Div Inspection Date 01/18/2011
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/T17
Dean Deibert Dean Deibert Van Jones Issued 8/7/2009
General Manager General Manager Environmental Manager Expires 1/31/2011
[phone] [phone] [phone] Classification Title V
Permit Status Active
Inspector's Signature-
'C� "6� Comments:
Date of Signature: AY\J '
NESHAP: Mr Diebert said that 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 '/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; a wipe rag is 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. Wadesboro seems to do a disproportionate
amount of feathers, likely due to having recently installed a new hydrolyzer.
III. INSPECTION SUMMARY: On 18 January 2011,Heather Hawkins and I, Robert Hayden, arrived at
Valley Protein to conduct the amoral compliance inspection. The wind was very light, and blowing from the
plant to Hwy 52, but we did not note any odor as we approached. We met with Dean Deibert, General
Manager, and James Hodges, Environmental Manager. We reviewed the records of observations,production,
fuel usage, CO and 802 emissions, and control device inspection and maintenance. We then toured the plant,
checked gauge readings and all emission points.
Topics discussed included the plant's wish to reduce the required ORP level (300mv). Plant personnel say
that other VP plants as well as the DuPont, the scrubber solution manufacturer, say that maintaining a 100 is
more than adequate. The solution is expensive, and some plants have a requirement only to maintain positive
ORP. I had spoken to Steven Vozzo (RAQS)before about this, and he was reluctant to lower the standard,
but I committed to discuss it with him again.
We also discussed the format the facility uses for routine reports. It seems convoluted, wastes much paper,
and is difficult to understand. Mr Hodges said that corporate requires much of the format,but he would try to
implement my suggestions. I committed to sending him a sample report and a link to the DAQ spreadsheet
for calculating and displaying 12-month rolling totals (which I sent on 19 Jan).
As usual, the only significant odor noted was just downwind from the wastewater tank. This same odor was
noted on Rt 52 after we left the facility,but was not offensive.
During the facility tour, the water feed pipe to one of the venturi scrubbers broke(had been leaking—got lots
worse)and was shut down. The control system continued to operate, and Mr Hodges asked about the air
quality implications. The physical consequence of the venturi not operating is that non-condensible rendering
emissions go directly to the boilers. The permit does contain pressure requirements for this control device,so
I advised Mr Hodges to treat it as an upset condition under 2D .0535, and we discussed those notification
requirements and 2010 ACC annotation. NOTE: Mr Hodges emailed me later that the pipe was repaired in
less than 4 hours and operational.
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)
C-5 One air cooled condenser
in series with
C-1 One venturi scrubber(minimum scrubber
E2,E3,E4- Feather and Blood Rendering process liquid inlet pressure 9 psig)with a
Mist eliminator
a,E4-b, consisting of:
E4-c,E5-a, C-2 venting to One cyclone(60 inch diameter)with a
E5-b,and either Mist eliminator in series with a
E6 a)Seven batch cookers CY-1 combination of three natural gas/fuel oil
E9****
b)One rotary steam tube dryer CM-1 /saleable fat-fired boilers
B-1 to B-3 or One packed tower scrubber(minimum
c)One feather hydrolyser
C-4***,**** scrubber liquid inlet pressure 3 psig)
C-3**** One venturi scrubber(minimum scrubber
d)One feather press
liquid inlet pressure 5 psig)in series with
EIO**** 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
E1 Rendering process consisting of:
One three stage slurry system evaporative liquidprlMistet elimissurenator
9 psig)with a
condenser cooker with post heater forced Mist eliminator
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)
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 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
One 320U cooker C-2 venting to a Mist eliminator
E7 either
CY-1 One cyclone(60 inch diameter)with a
CM_I Mist eliminator in series with a
B-1 to B-3 or combination of three natural gas/fuel
C-4***,**** off/saleable fat-fired boilers
One packed tower scrubber(minimum
scrubber liquid inlet pressure 3 psig)
Press/centrifuge process C-3**** One venturi scrubber(minimum scrubber
E8 liquid inlet pressure 5 psig)in series with

C-4***,**** One packed tower scrubber(minimum
scrubber liquid inlet pressure 3 si
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, 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,
13-4, 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, 13-5:
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 13-1 and 13-2, 0.318 lbshmnBtu for boiler B-3, 0.30 lbs/mmBtu for boiler
13-4, and 0.28 lbs/mml3m for boiler B-5.
IN COMPLIANCE—The highest AP-42 emission factor for the permitted fuels is 0.16 lbs/mmBtu;
natural gas is 0.007 Ibs/mmBtu for No. 6 and No. 4 fuel oil; animal fat oil is 0.05 lbshnmBtu. 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 Ibs/mml3m. 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 semiammal reporting.
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(11 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
(20 July),was complete and appeared legitimate.
3. 15A NCAC 2D .0521 CONTROL OF VISIBLE EMISSIONS—The visible emissions from
boilers 13-1,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.
IN COMPLIANCE—13-1, B-2, B-3 and 134 were operating on natural gas,with zero visible
emissions. While very little 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(20 July),
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.

IN COMPLIANCE—Other than a small quantity(less than 0.25%) of No. 6 oil mixed with animal fat
(FDA regulation), no oil has been combusted for over a year. The fuel records are well organized. The
last report was received on time(20 July),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.
IN COMPLIANCE—The monthly records seem complete but the format is cumbersome. Mr
Hodges said he was open to suggestions on improvement. Sulfur dioxide emissions were
approximately 0.13 tons for the 12 months ending November 2010; carbon monoxide emissions were
approximately 17 tons. The last report was received on time(20 July), 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, 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.
IN COMPLIANCE—NG combustion generates S02 levels generally less than 1 lb/day. The largest
emitting month in the last reporting period was in June 2010— 19 pounds—less than 1 lb/day.
B. One feather and blood rendering process consisting of one feather hydrolyses(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(CM1) in series with
three boilers (B-1, B-2, and B-3) or packed tower scrubber(C4), and one feather press (El0)
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(Cl)with a
mist eliminator(C2)in series with one 60-inch cyclone (CYI)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),
One fluidizer tank (El8) 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(CM1) 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(C3) 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(CI).
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(20 July), 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.
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(20 July), 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. The Permittee shall record all parameters, inspections and maintenance in a
logbook.
IN COMPLIANCE—We detected no rendering odor as we approached the facility. During the
inspection, I noted operating parameters on the control equipment as follows: Venturi Cl (9 psig
minimum) was operating at 20 psig, venturi C3 (5 psig minimum)was not operating (see notes on
malfunction—broken water pipe). The packed tower scrubber(3 psig minimum) was operating at 6
psig, and the inlets to crossflow scrubber C8 (13 psig minimum) were operating at 21 psig and 22
psig. ORP values were observed to be 391 mV(packed tower scrubber) and 398/482 mV(stages I
and II of cross-flow scrubber. 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, except those addressed as deviations when the DuPont solution was still being adjusted.
The last report was received on time(20 July),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.
IN COMPLIANCE—Zero No. 4 has been purchased or combusted since 2005. The last report was
received on time(20 July), was complete and appeared legitimate.

VI. 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 hanunennill/shaker screen
systems.
The chlorine dioxide system is still on the permit(insignificant) but has been removed.
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 operating in compliance with all air permit stipulations. There are no MACTS applicable
to the facility. Send Mr Hodges a sample semiannual report and the Excel template for calculating 12-month
rolling totals for S02 and CO PSD avoidance tracking. Talk to RAQS about how to explore a reduction in
ORP level in the scrubbers.