AQ_F_0400034_20091118_CMPL_InspRpt

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NORTII CAROLINA DIVISION OF Fayetteville Regional Office
AIR DUALITY Valley Protein Inc-Wadesboro Div
NC Facility ID 0400034
Inspection Report County/FFPS: Anson/007
Date: 11/20/2009
Facility Data Compliance Data
Valley'.Protein Inc- Wadesboro Div Inspection Date 11/18/2009
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Little Duncan Road Inspector's Name Robert Ilayden
Wadesboro,NC 28170 Operating States Operating
f Lat: 35d 2.1192m Long: 80d 4.9683m Compliance Code Compliance-inspection
SIC: 2077/Animal And Marine rats And Oil Action Code FCE
NAICS::3111613/Rendering and Meat Byproduct Processing On-Site Inspection Result Compliance
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Contact Data Permit Data
Facility Contact Authorized Contact Technical Contact Permit 06467/T17
Dean Deibert bean Deibert Van Jones
Issued 8/7/2009
Expires 1/31/2011
General Manager General Manager Environmental Manager
Class1- (704) Pe
rmit
Staituas Active
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Inspector's Signature: Comments:
CDateOf,Signature: 95f 0
t. 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 left(north) onto US52.
Go a few miles,then pass Triangle Brick on right. The entrance to the Valley Protein plant is on the right;
1 proceed down the road to the driveway to the office building on the left side of the parking lot/drivcway.
j SAFBTY: 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 boots' traction. An inspector is consciously or
I " subconsciously tentative about touching railing at a rendering plant, which could increase the chance offal Is.
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IL 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
j sold as it feed additive but can also be used as boiler fuel when fuel prices warrant. There are four
uncontrolled boilers that supply steam to the processes; additionally,boilers B-1, B-2 and 13-3 serve as odor
control devices. A fifth boiler is permitted as an emergency boiler. The primary control for the rendering
emission is the evaporation of condensibles, then oxidation within the boilers. An alternate scenario is
directing Lion-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. Weekly
I production is currently 10.5million pounds.
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Ilt. - INSPECTION SUMMARY: On 18 November 2009, Steven Vozzo, Greg Reeves and 1, Robert
Hayden, arrived at Valley Protein to conduct the annual compliance inspection and to observe a stack test
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(separate report). We mat with Dean Deibert, General Manager, And Jaynes Hodges,Environmental Manager.
We reviewed the records of observations,prodtiction,'fuel usage, CO and S02 emissions, control device
inspection and,mamteuance. We then toured the plant, and discussed the stack testing with the contracted test'
company personnel and Mr Van Jones(Valley Protein corporate office);
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' As we were ttijhing off US S2-onto the=plant accessroad;directly downwind from the plant,,we,notcd
mediurn-strong rendering odor,not quite reaching the offensive level. This was attrihutahlc to the facility's
need to c0turol odor through 016less effective scrubbers during the stack testing.
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We also discussed the new DuPont odor Control compound used in the scrubbers, The plant tested the
comp ound"for three months at end of200$ and'into January 2009, and has been generally pleased with the
results, .There have _ ei hnor issues maint'Aining;OkP above 300 mV and several instances ofinsfrumon"t
i failure(hourly averagmg and trending),`Tlre'cornpound is expensive, And plant and corporate personnel
believe that effective odor control can be achieved far below the permitted 300 mV ORp,level (sohrtion
I coneentratioti).,'We disco"s,64�how the 300,mV unlit could be clialiged,tlirotigh a4 'dditional test. '
IV. PERMITTED EMISSION SOURCES:
i
t olls"sion Control
Source GnrissiohSourceDescrlptlou ",llevice. CpotrolAeyice,ncscrtptfoti
ID No.
Two natural ga dNo, 2 fuel oil*/No, 6 fuel
oiU'Orr Specification recycled Np 4
B *d equivalent frrelofl/salcablefrt-fired N/A N/A"
13-2
boilers(33,0 million Btu'pGr liour heat:
i„nputrateeacIt)';, ,
One natural gas/No.2 lnel oil/saleable fat
B- ,
I NS 3 -fired boiler(48:4 ruilhon T3tu,per hour N/A N/A
I heat input)
lie,natural as, 2 fuel od/No. 6 fuel
B-4 oiUOn Specif" on recycled No,4 ; NIA N/A
equivalent fuel oil/saleable fat-fired boiler
million to per hour Beat input)
One natural gas/No,2 fncl oil/No.6 fuel
oil/On Specification recycled No.4 N/A NIA
' equivalent fuel oiNaleable fat-fired boiler
(29.3 million-Btu per Hour heat iupn) ;
' C.� One air Cooled condenser
Feather and Blood Rendering process
in scries with
E2,E3, E4- C-1 One venturi scrubber`(tnirrirnum snubber ,
consisting of:
a, E4-b; ' liquid inlet pressure9psig)With a,
E4-C,> S-a, Mist eliminator
ES-b and „ a)Sovcu batch cookers
E6 C2 venting to
One cyclone(60 inch diameter)with a
l E9**** either , Mist eliminator in series witlr a'
b)Otto rotary"steam tube dryer CY<1 ,Cortibination of three natural gaslfuel oil
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c)One feather hydrolyser, CM-1 . /saleable fat'--filed boilors
B-t to B-3 or One packed tower,scrubber(minimum
d)Oire feather press scrubber liquid inlet l>ressurc 3 psig) .
C-3**** One vcnturi soul bCt' mininiarnscrubbcr
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E1 p**** Inlaid inlet pressure 5 psig)in series with
C-4***, **** One packed tower scrubber(minimum
1 scrubber liquid inlet pressure;3 psig)
C-6 One air cooled condenser
in series with
E1 'Rendering process consisting of. C-1 One venturiescrubber(miniinum,scrubber
j One three stage shiny system evaporative liguidiulet pressure 9 psig),wnh a
condenser cooker With post licatcr forced Mist cliurinat,or ,
circulationchaml2er on 1"stage
C-2benting to One cyclone(60 inch diameter)with a
cithcr Mist eliminator;in series with, ,
Of-I cornbiruniori of three(3)natural gas/fuel,,
CM-1 oil/saleable fat fired boilers,
83 1 to T3=3 in One packed]o)' cr scrubber(miniinum,
C-4**"`,**** serubber liquid inlet pressure 3"psig) -
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E18 'One fltudizer tank,
'C-3**** One venurci scrtirbb"er(nrnirnum scrubber,-
liquid inlet pressure 5 psig) in series with
C-4*** M*** Onepacked-tower scrubber(mu'1 u11
r scrubber liquid inlet iressnrc 3 si k)"
One air cooled condenser
C-7 In series with, ,
! One venturi scrubber(nurumum`scrubbcr --
j C-1 liquid inlet,pressurc psig) in series with
1 - G-2 venting to ( a Mist climhiator
P7 One 320U cooker either
I C Y 1 One cyclone(60 inch diameter)with a
CrY1-1 -„ Mist eliminator inseries with a
B-t to B 3 or combination ofthrcc in n ral,gus/fuel
oil/saleable fat-fired boilers
One packed tower scrubber(minimum
scrubberliquid inlet pressure3 psig)
* One venturi scrubber (minimum scrubber
E8 Press/ccntrif4ge process' C-3 liquid inlet pressure 5 psig) in series with
1 C q ** **** One packed tower scrubber(minurium
scrubber li `irid inlet ressuic>3 ist�)
One,two stage,cross tlow type wet
scrubber,minimuru scrubber liquid)inlet
E22 Plafifroom air system C-8*** pressure l3 psig with mist eliminator,
utilizing clrlorinc dioxide or DuPout
AeY)Cone=ZA3001IS f
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V. APPLICAl3LEs AIR QUALITY REGULATIONS:
A: Two natural;gas/No: 2 fuel oil/No. 6 fuel oil/On Specification recycled No. 4 equivalent fuel
1 oil/saleable animal fatfired boilers, 33,minl3tweacl%13-11 and B=2,,one Q)NSPS natural"gas/No:2
fuel oil/salcable,animai fat tired boiler,48.4inmBtu,B-3, one(1)natural ens/No.2 fuel oil/Noi;6 feel ,
oil/On Specification recycled No 4 equivalent fuel oil/saleable animal fat fired boiler, 33.5 mnil3te;
B 4, and one natural gns/No2 fuel oil/No. a fuel oil/On Specification recycled No. 4 equivalent fuel,
I oil/Saleablefnt-fired boiler,29.3 mml3tu; E-5: "
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B. One feather and blood rendering(process consisting of one feather hydrolyser(E9) and seven batch
cookers (E2,U E4-a,E4-b, E4-e;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(C1)with a.mist eliminator
(I, ui series With one 60-inch diameter cyclone.(CY I)"with a lnist eliminator(CM[)m series"with
" three boilers;(B-i,B-2, and 11-3)or packed tower scrubber tC4);'and one feathcr press,(E 10)
controlled by'vcnturi sprubber(C3) in series with packed bed scrubber(04).
One rendering procoss consisting'oi'orre three stage slurry systom,evaporative condenser cooker(El)
controlled by"one air cooled condenser(CIS) in series with"onc 50 gpm venturi scrubber(0)'wi`th a
mist eliminator(C2),in series"with one 60-inch cyclone(cYl).with a mist elim�anator(OM I) inseries
with"three boilers(B-l;B=2, and B-3)or a packed tower scrubber(C-4)„',
One fluidizer tank(El
8)controlled by ventur i,scrubber(0)"in series with packed bed serubberi(C4), "
06020U,cooker(P)',eonHrolled by one air cooled condenser(C7) in series with one 50 gpm venturi
scrubber(0) with'a mist eliminator(C2)its series wit)i one 66=inch cyclone (CYl) with a mist
eliminator(CM7)u series'withthree boilers(B-1; 3-2,and 13-3)"or a packed lower Scrubber"(C-4),
f and
Onc centrifuge press(E8)controlled by venturi scrubber(C3)in serics with packed bed scrubber
(C4)...
j 1. 15A,NCAC 2D :0515 PARTICULATLS FROM MISCI YILANUOUS INDUSTRIAL
P994O ESS> S--`Emissions of particulate matter from those sourer$shall be controlled"by a series of
control devices(venturi scrubbers, cyclones and mist eliminators) and shall not excoed 4,10 * p
i this is acpomplrshed by properly rnaintoiniug Ure control devices, The Permitter shall:perforin a
I �"monthly visible inspection;including,411 ductwork and an annual internal inspection of condenser"
(C5),andvpnWriscrubbo"(6),
IN"CONIPLXANCPs-Daring,the inspection, all coutroi devices were operating except the boilers
I (because of fhesource testing). Ireviewed the I&M"records of the,control dcvicos and found"that the .
Permittee appearsto perform tlrp required montlily"inspections weekly.;,Each"inspection workshect is
� tailored to the control device. "
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2: ISA NCrSC,2D.0521 CONTROLOF VISIIILE EMISSIONS"—The visibloemissions from
these sources Shall notbe more than 20%opacity, The"Permittee shall obserVo4hese daily for
nbrmat VE
IN COMPLIANCE- During the;inspection,L observed no visible emissions froth ally,of the process,
E eniripment"or(hc control devices attached"to them. Daily VE(vs normal) is required oply when
combusting fuel oil,"but the facility checks all stacks daily regardhss of fuel, and logs results,
C., 'Multiple Emission"Sources"
1., 15A NCAC 2D .0539 ODOR CONT90L FOR FEED INGREDIENT MANUfACTl712ING
PLANTS,' The Petmittee shall ensure that odorous emissions ate controlled by control devices-as
j listed in the permit and the Permittee shall"install;operate and maintain parameter measuring and
recording devices for tlicse devices. All gases from plant room air, feather"and"blood rendering ano
rondering process shall Pass first through the condensers and their be incinerated at 1200 degrees for
0.3 seconds while(he boilers are not in low ire(or Treated in an equally effective rnanuer: All
expeller units shall be properly hooded and all exhaustgases directed to odor control e(juipment; "The"
Perrnittep shall take reasonable precautions to prevent odor discharge during Handling,transportation
I and storage of incoming materials. The Permittee shall ensure that all odor control devices arc ,
inspected;maimaincd and operated properly; condensers inspected monthly, scrubber nozzles cleaned
monthly, generation units calibrated monthly, and a seini�anjnn l internal inspection for all control`
deniers. The"Pcrniiriee shall ensure the venturi(C-1) inlet water;pressurc at a 9 psig minimum,the
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1;" 15A NCAC 2D .Q503 PARTICUI ATES,FROM FUEL BURNINGINDIRI CT HEAT
EXCHANGER§=Emissions of paificulate matter from boilers into the atmosphere shall not exceed
0.367 lbs/mtnBtu"for boilers B-1 and B-2, 0.318 Ibs/mmBtu for boiler B-3; 0.30 lbs/rnmBla for boiler
13-4, and 0.28 lbsfrmmnBhl for boiler 13-5.
IN COMPLIANCE-"The highest AP-42"emission factor for"the permitted firels is 0.16 lbs/nunBtu; "
nattiral gas is 0.0071bs/rnmtu fo BrNo."6 and"No;4 fuel oili animal fat Hs 0,05 lbs/mmBtu- The
facility,has not burned,hiel oil for over a year,"
2 :15A NCAC 21) .0516 SULFUR DIOXODE ]EMISSIONS FROM,COMBUSTION " "
SOURCES—Suifui dioxide emissions shall not exceed 2.3 Ibs/mn�Btu.The Permittee shall"monitor
C the sulfur content of the No: 6"fuel oil and recycled"No.4 fuel oil by-using fuel oil supplier
certifications per ship nentroceived; the"sulfur content of the No. 6 is limited.tq 2.1 %and the ' "
recycled"No; 4 is2.0%o.
IN COMPLIANCE-The facility has not burned fuel.oil for over a year: Previous fuel oil supplici'
certifications showed`sulitn`content of;No,6 fuel ranging front 1:06% to 1.14%. Zero Na'A fuel has
been purchased or combusted since 2005.
3; 15A NCAC 2D :0521 COlY'i`ROL OF VISlI3LE EMISSIONS " The visible emissions from
boilers 13 B-2, B-3 and,13 4 shall not be more than 20%opacity, The Permittee sinill also observe
the,visible emissiairfrtim the bo l�rs"firingon No."6 firel oil, recycled No:4 fuel oil,:No. 2,bel oil and
animal fat oil"daily agamst"nornml", "
`INCOMPLIANCE,--During' the inspection,T observed boilers B-f,B-2,'and"B-3 fitmg natural gas, "
with zero visible emissions:.While no oil,has been cofnhusted in over a year, the facility checks UE "
daily; VE log,is woll organized and showed no exeoedonces,
A', " 15A NCAC. 2D .0524 NSPS 40 PART 60 SUBPART Dc The'maxiin in sulfur content of any,
" ail cotnbusted"in boiler B-3 shall not exceed 0.5%, and the maximum VD shall be 20% The
P"ermittee shall"record find maintain record9 gfthe"amounts ofNo, 2.ftrel oil combusted during each "
month and 9fthe sulfur content through fuel supplier certifications.
IN COMPLIANCE,-Other than a small quantity(less than 0:25%) of'N6.2 oil mixed with amoral"fat
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(FDA regulation),no,oirbas been eombusted for over a yeas. The old"fuel rccords are well organized.
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5." I5A NCAC 2D .0530 P12EUENTION�OC"SIGNIFICANT DE'1'ERIOI2ATION "Boilers"I31, "
13 24 B-3, 3 4 a4iIB 5 shall discharge less than 250 torts of sulfur dioxide'and carboy monoxide per
t consecutive twelve-month porio& The Permittco shallrecord the amounts of natural gas,"No.-2 fuel
oil;No:6"f rel oil;On;Specificat op"No. 4 recycled fuel oil, and animal fat oil combusted in the
j boilers each month; the Perini shaft"also ealculate`the apiounts of carbon monoxido and sul fur
'r dioxide'emittcd each month.
i IN COMPLIANCE"—The monthly records are"complete in order. Sulfur dioxide"emissions were
approximately 62 tons for the 12 months ending Jung 2009; carbon monoxide emissions were-
approximately 7 tons.-
I The tracking system format is"overly lar`ge.and convoluted:" T promised to scud Mr Ilodges a smaller,"
more conveniept and efficient model.
I 6,� 45A NCAC 2D:0$01.EMISSION CONTROL STANDARD—The daily"emission-of sulfur,
I dioxide from boilers T3-1,B-2,"13-3, B-4 and I3-5,shall not exceed 3,644.49 pounds per day.,
IN COMPLIANCE'-NO combustion generates S02 levels generally"less Utah 1"ib/day, Thelargest
omitting month in the last reporting period was in July 2008 1,809 pounds.,'fhe facd ity,is
needlessly calculating daily S02 emissions;the-permit allows calculations based on the PIS
! avoidance(monthly)calculations,divided by 30: ;

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i venturi C-3 inlet water pressure at a 5,psig minimum the packed bed scrubber C 4 inlet water
pressure at a psig minimum, the cross-flow (C-8)generation unit at a u 300 OR1' minimum and the
scrubber inlet water pressure at a 13 psig mi nmuni, The Permittee shall monitor the boiler operating
parameters once per day. The Permitter shall record all parameters,inspections and"maintenance in a
logbook.
[N COMPLIANCE=We'did iiotice off-site rendering odor as we approached the facility;it was not
at an offensive level,and was attributed"to the operation of the scrubber controls instead of the
" prefem;ed boiler incineration. Near and within the various buildings however; the odor became quite
" strong;,the most pungent odor oecurredfnside the feather:hydrolysis room.,'purnig the inspection, I
rioted operating parameters on the cot}trot equipment as follows: Venturi C1 (9 psig minimums) was
operating at 20 p51g, vonturi 63 (5 psig:minimunr)was operating at 18 psig, the packed tower
scrubber(3"jisrg minimuin)was operating at 6 psig, and the inlet s to crossIlow scrubber" C (I3 i5sig" "
minimum)"were operating ali 15 psig and 17 psig." ORP,values wore"observed to be 35 f mV(packed
i tower scrubber)=and 38.61/343 mV (stages"I and II of cross- ow scrubber.'ValleyTrotein has received
j rm odof complaints recently, Tlie pressures.are monifoied ruid,recorded each"shift; the ORPs are on
i continuous strip charts. "Ail showed compliance;eXccpt those addressed as deyiations"wheii.the
DuPont solution was still being.adjusted.
There was discussion regarding the implications of the permit language when the ORP drops below
300"mV. Steven Vozzo clari{ied that itiyas understood that actiofi must be taken imniodiatcly on
discovering OgP below the limit; there was no 4-hour grace period. The plant.personnet agreed that' .
was the intent, One minor issue is that the permit uitcnded'to"stipulato waudible 41artr if,ORP i3fops
below 300 n V. Mr,Deibcrt e0min4ed to installing an alarin,
2r 15A NCAC"2Q:Q,317 AVOIDANCE CONDITION I?OR 15 A-NCAC 11) .1100 CONTROL "
OF TOXIC AIR POLLUTANTS (State"Only Requirement)—The Permittee shall only combust"',
i recycled N .•4 ofuel oil that mectsthe specifications listed in the;permit. The"Permittce shall record
the amount recycled No: 4 d(divefed to and cornbusted of"the facility and retain the results of
analytical testing. "
' IN CO 4 1?"LlANCI;—Zero No. 4 has been purchased or combusted since 2005."
VI. "PERMIT EXEMPT EMISSION SOURCES:
A, Ono Ioadout operation;IE2L1,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,T132A.2,,andIF24.2, consisting of three hammermiil/shaker screen
i systems;,
The chloride dioxide system is still on the ti6ni it(insignificant)but has been re owed.
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VII. "COMPLIANCE HISTORY: In September 2002,FRO issued an NOV/NRL for offensive off-site
odorand (ailure,to record scrubber pH and flow rate; FRO rescinded the NRE in November 2002, In March
(" ` 2002;FRO issued an NOV,fox Tate reporting,
VIH: CONCLUSIONS AND,gt NIMENI)ATIONS:At the titne-of the Inspection,Valley Protein"
appeared to be ope•ating iiv, omlrliance with all air permit stirpnlations.'There are no MALTS applicable
to the facility.'lollow'up on the installation of an audible alarm on the.ORP monitoriug system, Send Mr,
dodges ao Excel template for calculating_12-month-rolling"totals"for S02 and CO PSD avoidance tracking.
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