AQ_F_0400039_20221208_PRMT_PmtRvw

NORTH CAROLINA DIVISION OF Region: Fayetteville Regional Office
AIR QUALITY County: Anson
NC Facility ID: 0400039
Application Review
Inspector's Name: Mike Turner
Date of Last Inspection: 09/15/2021
Issue Date:12/O8/2022 Compliance Code: B/Violation-emissions
Facility Data Permit Applicability(this application only)
Applicant(Facility's Name): Perdue AgriBusiness-Ansonville SIP: X
NSPS:
Facility Address: NESHAP: X
Perdue AgriBusiness-Ansonville PSD:
2755 Old Hwy 52 West PSD Avoidance:
Ansonville,NC 28007 NC Toxics:
112(r):
SIC: 2048/Prepared Feeds Nec Other:
NAICS: 311119/Other Animal Food Manufacturing
Facility Classification: Before: Small After: Small
MODIFICATION
Fee Classification: Before: Small After: Small
Contact Data Application Data
Facility Contact Authorized Contact Technical Contact Application Number: 0400039.21A
Joe Potts Sharon Clark Joey Baggett Date Received: 11/16/2021
Plant Manager SVP Regulatory Affairs Regional Environmental Application Type: Modification
[phone] &Compliance Manager Application Schedule: State
2755 Old Hwy 52 W [phone] [phone] Existing Permit Data
Ansonville,NC 28007 6906 Zion Church Road 242 Perdue Road Existing Permit Number: 07495/R09
Salisbury, MD ofield,NC 27922 Existing Permit Issue Date: 07/26/2017
21802+1537 Existing Permit Expiration Date: 06/30/2025
Review Engineer: Taijah Hamil Comments/Recommendations:
Issue 07495/R10
Review Engineer's Signature: Date: Permit Issue Date:12/08/2022
12,1 b@ Permit Expiration Date:06/30/2025
1. Purpose of Application
Perdue Agribusiness—Ansonville is an existing feed mill operation located in Ansonville, Anson
County. The facility has requested a modification to their current air permit to include the use of
Termin-8 in the feed production process. Termin-8® is an antimicrobial preservative that will inhibit
mold growth and maintain feed and feed ingredients Salmonella negative(See Section 5 for more
detail). The facility is also requesting updates to their permitted source table.
The facility is classified as Small.
The application did not contain any confidential information.
There are no facility file"Pink Sheet" items to be addressed in this permit application.
The facility contact for this application is Joey Baggett, Regional Environmental Manager,(252-348-
4383).

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Permit R10 Review
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2. Facility Description
Perdue AgriBusiness—Ansonville produces various animal feed mixes, primarily for the poultry
industry. Various grains, animal byproduct meal, and mineral supplements are received at the facility
and blended to produce the feed mixes to customer specifications.
Perdue utilizes Termin-8"as an additive to the blending operations. Termin-8® is an antimicrobial
preservative that will inhibit mold growth and maintain feed and feed ingredients Salmonella
negative. Termin-8®(stored in 2,400 lb totes at the facility) is applied by atomizing nozzles inside the
mixer(ES ID No. J),which is a closed vessel. The operation at this facility is mixing and blending
only. The material is processed at ambient temperatures and not heated as in other operations that use
Termin-8®. Mixed feed is loaded out via truck for delivery to the customer.
Note that this facility is technically not subject to the Area Source NESHAP for Prepared Feeds
Manufacturing, Subpart 7D, because they currently do not use mineral additives that contain the
compounds that trigger this stipulation(Manganese and Chromium). However,the facility wanted to
stay consistent with other Perdue Agribusiness facilities and have the option to use these compounds
if permitted in the future.
3. Zoning
A Zoning Consistency Determination is not required for this permit action.
4. Application Chronology
10/05/21 Gregory Reeves of FRO(DAQ) received a phone call from Joey Baggett, Perdue
AgriBusiness, Regional Environmental Manager, inquiring about whether an air
permit was required for the treatment of feed mixes with Termin-89 liquid
antimicrobial preservative that the facility had already installed and was operating.
10/07/21 Mr. Baggett provided Mr. Reeves with annual process throughputs for the feed mixes
using Termin-89, addition rates of Termin-89,retention rates of Termin-89 in the
finished feed mix, and hourly process rates for the feed mixing operation.
10/18/21 An NOV was issued for"Emissions Rates Requiring a Permit,"due to calculations
they provided indicating Formaldehyde broke TPER.
11/16/21 FRO received the NOV response which included the complete permit application with
all required forms,emission calculations and toxics modeling. Modification fees were
required. There was no request to keep any information confidential. The application
appeared to be complete for processing.
11/16/21 FRO sent the facility a letter acknowledging receipt of the permit application.
11/16/21 FRO sent emission data to The Washington Regional Office (WRO)to review the
emission rate value that would be needed for the modeling review.There were several
feed mills in the State that had installed this chemical application system or had
submitted applications to do so and their emission rates varied depending on their
estimated percentage of formaldehyde released to the atmosphere. These data was

Perdue Agribusiness-Ansonville
Permit R10 Review
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reviewed by WRO, SSCB and product manufacture to decide what value would be
used in all permit applications.
PERMIT APPLICATION CLOCK OFF
11/17/22 Jeffrey Cole called Rebecca Day, Environmental Manager and informed her that DAQ
was close to deciding on a Termin-89 release rate percentage which would likely be
close to(but may be lower than)the release rate the company had presented in their
permit modification application,and which had already been modelled. Mr. Cole
asked Ms. Day if the company wanted FRO to issue the permit based on their currently
submitted emission rate and associated modeling,or if they wanted to wait on the
DAQ approved emission rate.
11/21/22 Ms. Day emailed Mr. Cole and confirmed that the company would like us to process
the permit modification using the 0.05%release rate for Termin-8 and not to wait on
the final DAQ approved emission rate.
PERMIT APPLICATION CLOCK ON
12/05/22 Taijah Hamil, FRO DAQ, spoke with Rebecca Day, Environmental Manager, and
Yvonne Greene, Production Supervisor,to verify the location of bag filters and
potential maximum throughputs. See Sections 5 and 7 for more detail.
5. Changes in Equipment, Emissions and Regulations and PE Review Requirements
This permit modification application is for a revision to their current air permit to include the use of
Termin-8' in the feed production process. Termin-8® is an antimicrobial preservative that will inhibit
mold growth and maintain feed and feed ingredients Salmonella negative. The liquid preservative
will be stored in 2,400 lb totes at the facility and will be applied by atomizing nozzles inside the
mixer(ES ID No. J), which is a closed vessel. This preservative will introduce new pollutants,
methanol, and formaldehyde,to the facility. See Section 7 for more detail.
The facility has requested that the permitted source table be updated, as the current listing is incorrect.
This information was confirmed by Rebecca Day, Environmental Manager, and Yvonne Greene,
Production Supervisor.
• Note that the has an inoperable hammermill on site, that was once permitted. It was
controlled by CD-3. The hammer mill was never utilized; therefore, it was removed from the
permit in 2005. CD-3 should have been removed from the permit at that time but was
attached to the wrong source. The facility has not been able to dismantle and sell
incorrectly
g tY
this equipment, so it is still located on site.
• Currently,the three (3) storage silos(ID No. I)are listed as being controlled by CD-3 and
CD-5. However, CD-3 was installed on the hammer mill (as noted above). The railcar and
truck receiving pits are controlled by CD-4. The silos are also associated with CD-4 because
they are filled by the leg elevators which are loaded from the receiving pits. CD-5 is actually
installed on the pneumatic truck receiver(ID No. Q. These changes have been updated in
IBEAM.
The 02D .0521 "Control of Visible Emissions" stipulation has been updated.

Perdue Agribusiness-Ansonville
Permit R10 Review
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The 02D .1100 "Toxics Above TPER Limits" stipulation has been incorporated into the facility's
permit.
A PE Seal is not required for this permit action.
The facility's permitted emission sources are as follows:
Emission Emission Source Control Control System
Source ID Description System
Description
No.A Railcar, choke-fed receiving pit within a two sided,roofed
enclosure
No. B Truck receiving pit within a two sided,roofed enclosure Fabric filter
CD-4 (620 square feet of
�
filter area)
Three storage silos,two with a capacity of 11,300 cubic
No.I yards and one with a capacity of 9,600 cubic yards
(t
I Fabric filter
No.C Pneumatic truck receiver I CD (245 square feet of I
filter area)
No.H Truck loadout operation within a three-sided,
(NESHAP 7D) roofed enclosure
N/A N/A
No.J �
(NESHAP 7D) i Mineral Additive Mixing and Handling System
The facility's insi nificant/exem t activities are as follows:
Source xemptontegulation ' Source of Ties 9 Source of Title V
I-S 1.
Pollutants?
Truck loadout spout on silo 1
2Q .0102(h)(5) No Yes
I-S2 I 2Q .0102(h)(5) No Yes
Truck loadout spout on silo 2 1
I-S3 2Q .0102(h)(5) j No i Yes
Truck loadout spout on silo 3 I
6. NSPS, NESHAP, PSD, 112(r) & Attainment Status
• NSPS—There are no current NSPS Regulations that are applicable to this facility.
• NESHAP—The facility is subject to NESHAP Subpart DDDDDDD(7D)"Area Source
Standards for Prepared Feeds Manufacturing"because it is an area source of HAP that uses
materials containing Manganese in excess of 1.0%concentration. No other current NESHAP
regulations apply to the facility. This regulation applies to the Mineral Additive Mixing and
Handling System and the Truck Loading operations.
• PSD—The facility's potential emissions do not exceed PSD permitting thresholds.

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Permit R10 Review
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✓ Anson County has not triggered PSD Increment Tracking.
• 112(r)—The facility does not store any of the listed 112(r) chemicals in amounts that exceed the
threshold quantities. Therefore,the facility is not required to maintain a written Risk
Management Plan(RMP).
• Attainment status—Anson County is in attainment.
7. Emissions Review
CY 2016 teal Before Potential After
Pollutant Actual Emissions Controls/ Controls
Limitations Limitations
ro. ... . :,. �.. tonston
aik s/yr tons/yr
—PM(TSP) 1.76 48.11 1 0.05
F_
PMio 0.44 12.2 0.01
pMa.s 0.10 � 1.6 �� ...Y 0
f
VOC -* 6.1 F .1
* Since the facility never emitted any VOCs prior to installing Termin-8®,actual VOC emissions are not reported in this
CY.This permit revision modification will result in VOC emissions.
Actual emissions were taken from the CY2016 A EI as submitted b the facility. Potential PM
Q Y ty
emissions before and after controls were calculated using maximum potential throughputs and AP-42
Ch. 9.9.1 factors. Emission calculations assume a maximum throughput of 876,000 tons of feed,
which is the limiting factor of the facility, due to the mixing and handling system being able to
produce 100 tph of feed. The mixing and handling system is currently permitted to run at 70 tph, but
after conversations with Rebecca Day, Regional Environmental Manager, it was confirmed that the
source only runs at 70 tph but has a maximum rate of 100 tph. A control efficiency of 99.9%was
used for the fabric filters. Potential VOC emissions before and after controls were taken from
emissions calculations provided by the facility in the permit application. See Appendix A at the end
of review for emission calculations spreadsheet.
8. Air Toxics
This facility previously had not triggered an air toxics review. This application results in a
facility-wide increase in toxic emissions of formaldehyde due to the addition of Termin-8 in the feed
production process. After the review of the emission calculations from the Termin-8 process, it
showed that this facility broke TPER for formaldehyde emissions. Facility submitted formaldehyde
emission rates were based on a production rate of 70 tph, but the maximum potential production rate
is 100 tph. The maximum potential formaldehyde emission rate can be calculated by the following
equation:
(Maximum process rate,tph) X (Termin-8 added per ton of feed, lb/ton) X (percent of formaldehyde
in Termin-8) X (formaldehyde release rate)=Max potential formaldehyde emission rate
Maximum process rate= 100 tph
Termin-8 added per ton of feed=6 lb/ton
Percent of formaldehyde in Termin-8=33%

Perdue Agribusiness-Ansonville
Permit R 10 Review
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Formaldehyde release rate= 0.05%
This results in a current maximum potential formaldehyde emission rate of—0.1 lb/hr.
The Permittee submitted a toxic air pollutant dispersion modeling analysis to the Air Quality Analysis
Branch(AQAB)dated December 21,2021 for the facility's toxic air pollutant emissions as listed in
the below table. A review of this modeling by Matthew Porter of AQAB dated January 7
2021 indicated that the respective AAL for this toxic will not be exceeded at the property boundaries. L
Modeling was maximized to show emission rate equating to 99%of AAL.
Modeled Release AAL ...�
Pollutant %of AAL
Emission Rate(lb/hr) (mg/m3,
Formaldehyde 1.46 0.150 ; 99
As a result of the Air Dispersion Modeling Analysis,a 15A NCAC 02 D .1100 condition was added
to the permit.A 15A NCAC 02Q .0711 toxics condition has not been incorporated into the permit
because there's no history of any other TAP being emitted at the facility.
9. Compliance History
10/18/21 NOV issued for emissions rates requiring a permit.
09/15/21 Mike Turner conducted the latest compliance inspection and found the facility to be
operating in apparent compliance.
05/11/17 Jeffrey Nelson and Mike Thomas conducted a total of four(4)compliance inspections.
Through The facility was found to be in apparent compliance each time.
09/02/20
10. Stipulation Review
z
Regulation Affected Sources Emission Limits or Requirements
_- �_______. _--____-_._._____
15A NCAC 2D.1&2 Facility-wide Permit Renewal and Emission Inventory Requirement
�- E=4.10*(P)0-" for P<30 tons/hr or
15A NCAC 2D.0515 Facility-wide E=55*(P)0-11—40 for P>30 tons/hr
15A NCAC 2D.0521 Facility-wide VE<20%opacity
15A NCAC 2D.0535 Facility-wide i Excess Emissions Notification Requirement
F1 NCAC 2D.0540 Facility-wide Fugitive Dust Control Requirement
Fabric Filter Requirements T
15A NCAC 2D.0611 CD-4 Periodic I&M per manufacturer recommendations
CD-5 Annual internal inspection
Recordkeeping

Perdue Agribusiness-Ansonville
Permit R10 Review
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E Control of Toxic Air Pollutants
15A NCAC 02D.1100 Facility-wide Facility Wide Emission Limit for
i
Formaldehyde 1.46 lb/hr
Operations Restrictions
Management Practices
15A NCAC 2D.1111 No.H Monitoring Pellet Cyclone Process
NESHAP 7D No. J Recordkeeping
Initial Notification
Notification of Compliance Status
Annual Compliance Certification
15A NCAC 2D.1806 Facility-wide No objectionable odors beyond property boundary
11. Changes to Permit Writer
• Highlighted headers, adjusted column widths and borders for improved clarity and appearance.
12. Comments and Recommendations
• Recommend issuing permit no. 07495R10 to Perdue Agribusiness—Ansonville(0400039).
Review Engineer: Date:
Permit Coordinator: Date: J11 ZZ
AQ Supervisor: Date: 12,1V Zo Z'Z--

Perdue Agribusiness-Ansonville
Permit R10 Review
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Potential Particulate Emissions Calculations-Perdue Agribusiness-Ansonville
Permit R10 Review
Maximum Control Potential Emission Before Potential Emissions After
Emission Source Emission Factors'
Throughput Efficiency Controls Controls
tons/yr % lb/ton tons/yr r tons/yr
�- I'm I P M ,, I'm,, I'm P M,(, P M.1; PM P M 10 P M 2.5
F.............
lRai Receiving 876,000 99.9 _ 0.032 0.0078 0.0013 14.0 3.4 0.6� 0.0140 j 0.0034 0.0006
F­Truck Receiving..� I I
"'
Hopper3 _�788,400 99.9 �0.035 0.0078 0.0013 13.8 3.1 F--"--0.5 0.0138 0.0031 0.0005
-F
Straight3 87,600 99.9 0.18 0.059 0.0013 7.9 2.6 0.1 0.0079 0.0026 0.0001
(End Dump)
Pneumatic 44 1,000 99.9 0.061 0.034 0.01 0.0 0.0 0.0 0.0000 0.0000 0.0000
receiver
Truck Feed Loadout 876,000 0 0.0033 0.0008 0 1.4 0.4 0.0 0.0014 0.0004 0.0000
(finished)
Three(3) Storage g76,000 99.9 0.025 0.0063 0.0011 11.0 2.8 0.5 Fo
0 1 10 0.0028 0.0005
Silos _ _
I Totals I ^� � 48.1 12.2 1 1.6 0.048 0.012 0.002
' Maximum potential throughput limited by mixing and handling system(100 ton/hr at 8760),which only emits VOCs(total of 876,000 tons/yr).
Z Emission factors from AP-42,Table 9.9.1-2
3 All grain received by truck goes into one pit(Truck Receiving controlled by a fabric filter),-90%of material received by truck are hopper trucks and-10%are
straight(end dump)trucks.
I
a Facility only receives material by pneumatic truck 2-3 times a year. Based on actual calculations from 2016 AQEI, it was assumed that-1000 tons/yr of
material can be received.