AQ_F_0800109_20150319_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Washi.,._a Regional Office
AIR QUALITY Perdue Foods LLC-Lewiston
NC Facility ID 0800109
Inspection Report County/FIPS:Bertie/015
Date: 03/19/2015
Facility Data Permit Data
Perdue Foods LLC-Lewiston Permit 10265/ O1/
3569 Governors Road Issued�2/14/201
Lewiston Woodville,NC 27849 Expires 9/30/2017
Lat: 36d 8.6751m Long: 77d 12.8460m Classification Synthetic Minor
SIC: 2015 /Poultry Slaughtering&Processing Permit Status Active
NAILS: 311615/Poultry Processing Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP/112r
Joey Baggett Wayne Black Joey Baggett MACT Part 63: Subpart ZZZZ
PAB Environmental Director Perdue PAB Environmental
i Manager Agribusiness Manager
[phone] [phone] [phone]
Compliance Data
Comments: The facility appeared to operate in compliance with all applicable air
quality regulations and permit conditions at the time of inspection. Inspection Date 03/17/2015
Inspector's Name Betsy Huddleston
Inspector's Signature: Operating Operating Status Operating
Compliance Code Compliance-inspection
Date of Signature: 349l10;S Action Code FCE
On-Site Inspection Result Compliance
Total Actual emissions in TONSIYEAR:
TSP S02 NOX VOC CO _T PM10 * HAP
Previous inventories are found under facility ID 0800081,which is now Valley Proteins. The emissions inventory for this permit is
due 07/02/2017 with the renewal application.* *Hi hest HAP Emitted (inpounds)
Directions
Perdue Farms operates a chicken processing plant located on Highway 308 West, Lewiston Woodville, Bertie
County. Directions from the Washington Regional Office are as follows:
• Take Highway 17 N to Windsor and go through the first stoplight(funeral home on the right).
• At the second stoplight,turn left onto Highway 308 West.
• Stay on Highway 308 to Lewiston Woodville. Cross over Highway 11. The plant is on the
left just outside town.
• Stop at the second entrance to the facility where the tractor trailers are entering(guard gate).
Be prepared to show identification and to open the car trunk for inspection.
• Drive straight back through the yard. The environmental office is a white building on the
left,next to the wastewater treatment system.
Safety Concerns
• There are tractor trailers frequently coming and going from the facility, so be careful when
driving on the facility grounds. The bird receiving area is very dangerous with the trucks and
forklifts unloading bird cages. If it's necessary to walk through the receiving hanger,wear a
reflective vest and stay close to the escort. Make eye contact with the drivers.
• Hearing protection,reflective vest,hard hat,safety glasses and safety shoes are required.

Permit History
• 10265ROO was issued on 10/17/2012. Perdue Farms had a Title V permit for a chicken
processing plant and a rendering plant(Facility ID 0800081,Permit No. 03085T28). Perdue sold
the rendering plant to Valley Protein and retained the chicken processing plant. As a result, Title
V Permit 03085T29 was issued to Valley Protein,and Perdue was issued a new Synthetic Minor
permit and premise number.
• RO1 was issued on 2/14/2013 for a name change to the facility.
Process Description
• There are three receiving lines with hoods over each loading area. Birds are unloaded in boxes from
trucks. DOA birds are collected in a dumpster for disposal off-site(rendering).
• The birds are loaded into the hanging system(3 hanging rooms). Perdue employees hang the
chickens by their feet onto moving racks. The room air goes to three baghouses that remove feathers
and particulate.
• Chickens' necks are slit,and the chickens are bled out(blood is collected for use at the rendering
plant). The feathers(propane-fired singers are used)and heads are then removed.
• Organs and feet are removed in the evisceration process. The feet are a saleable product. The organs
and the meat are thoroughly inspected. Rejects are sent to the rendering plant.
• In evisceration, all water is treated with aparacetic acid to kill bacteria. The plant has previously used
tri-sodium phosphate. They can also use chlorine dioxide and hydrogen bromine.
• The meat is transferred to the chillers(ammonia system). A maximum of 87,163 lbs of ammonia can
be stored on-site. Ammonia loss would most commonly occur through seal leaks. There is very little
loss from a shutdown. Perdue purges ammonia back to the storage tank, and then seals the tank off
during shutdown.
• Inspectors grade the meat. The meat is cut into parts,marinated,packaged,and shipped.
• The plant generates about one truck of rendering material per hour.
Permitted Sources/Inspection Observations
I performed records review and physical inspection of the sources and controls on March 17,2015. The
inspection was completed with assistance from Mr.Joey Baggett, Mr.Tim Mizelle and Ms. Ashton Weller.
Calendar year 2014 and January-February 2015 records were reviewed.
The following table contains a summary of all permitted emission sources and associated air pollution
control devices. Some observations from the inspection are noted in bold print.
__.__......_ __._..__........
_�. __........ __.__ _____._.._.....__
Emission Emission Source Control Control System
Source ID Description System ID Description
j v ES-1 jThree(3)live poultry receiving and handling CD-1 bagfilters(2,800 square feet of filter
ES-2 systems CD-2 area,each)These units run at about
ES-3 CD-3 18,000 ACFM each. The exteriors of
3 the bagfilters/ductwork appeared to
be in good shape. All of them have
pressure gauges(reading<3 inches
. ....
-- _ ... ..._..
each).VE m fro each bagfilter was 0%.
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i
Emission Emission Source Control Control System i
Source ID Description System ID Description
ES-4 Two(2)natural gas/No. 6 fuel oil-fired boilers
ES-5 (20.3 million Btu per hour maximum heat input
(NESHAP) capacity)The boiler plates say the heat inputs N/A N/A
are 20.9 MMBtu/hr.One of the boilers was
firing fuel oil during the inspection.
111!
ES-22A Two(2)diesel-fired emergency/peak shaving
ES-22B generators(2628 horsepower engine output) N/A N/A
1 (NESHA.P) The engines were not operating during the
I :inspection. They are for emergency use only.
No#6 fuel oil was combusted in 2014. Natural gas usage for 2014 was 153,940 mcf. 21,440 mcf has
been combusted since January this year. Some fuel oil has been combusted since January 2015 (24,712
gallons). The shipping manifests for the fuel oil cite a sulfur content of 0.47%.
Natural gas usage is metered. Fuel oil shipments are tracked by Perdue's accounting department in
Salisbury. Billing statements are kept on file.
Perdue wishes to begin burning No. 2 fuel oil as a backup to natural gas. We discussed that a permit
modification may not be needed to begin usage since they are already permitted for No. 6 fuel oil. Joey
will be mailing a request letter in the next week.
The maximum pressure for each boiler is 150 psi. The boilers were constructed in 1975. Perdue has
computerized panels that provide instantaneous operational data for the boilers.
Parameter Boiler ES-4 Boiler ES-5
Steam pressure 109.1 109.7
Visible emissions 0% 0%
Fuel No. 6 Oil Natural Gas
Steam 13,8261bs/hr 6,3001bs/hr
Stack temp 3630F 381OF
Oxygen 5.5% 4.3%
95,066,392 chickens went through the processing facility in 2014(compared to 87,728,898 in 2012 and
96,650,292 chickens in 2011).
The live poultry receiving and handling systems(ES-1,ES-2 and ES-3)are equipped with bagfilters to
control particulate emissions(mostly from feathers). They were operating during the inspection. The
bagfilters appeared to be in good physical condition. Pressure drop on each bagfilter was no more than 3
inches. These bagfilters have a stainless steel filter system that provides additional air exchanges in the
hanging room and coverage over a larger building area. The collection barrels are emptied nightly.
The following list of insignificant sources is attached to the permit:
Source Exemption
Regulation
IES-6-refrigeration system 12Q.0102(c)(2)(E)(i)
IES-7-propane-fired singers for poultry feathers(4.4 2Q.0102(c)(2)(E)(i)
million Btu per hour maximum heat input)
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It is my understanding that no pnysical or operational changes made to thc insignificant sources. I did not
physically inspect the insignificant sources. All of the emissions from the singers come solely from
propane combustion. 59,340 gallons of propane were combusted in 2014(58,963 gallons in 2013).
The only regulation that applies to the refrigeration system is 112R(discussed in the Regulatory Review
below). A maximum of 87,163 lbs of ammonia is stored on-site. Perdue figures the loss of ammonia
based on what they have to replace. 13,022 lbs were purchased/emitted in 2014(compared to 12,119 lbs
of ammonia purchased/emitted in 2013 and 24,523 lbs in 2012).
Applicable Reeulations/Reaulatory Review
2D.0202 "Registration of Air Pollution Sources"
The Director has the authority to require the registration of air pollution sources, and require them to
submit information about the source. It is under this Rule that the Division is requiring facilities to
submit an emissions inventory 90 days before a Permit expires. Perdue submitted an annual TV
inventory on 6/26/2013 because it held a Title V permit up until October 2012. The processing plant
emissions are for all of 2012,but the rendering emissions were covered under Perdue until October 17,
2012. The inventory emissions were combined with emissions calculated by Valley Protein for October
17-December 31, 2012 in IBEAM for facility ID 0800081. The next inventory will be due with the
permit renewal application due in July 2017.
2D.0503 "Particulates from Fuel Burning Indirect Heat Exchangers"
The boilers have never been tested for particulate. ES-4 and ES-5 each have an emission limit of0.42
lb/MM Btu. Worst case emissions are from fuel oil combustion.
Total estimated emissions using AP-42 (boilers<100 MMBtu/hr,worst case assuming all No.6 oil use):
40,600,000 Btu/hr(gallon/151,000 Btu)(10 lb/1000 gallons)=2.7 lbs/hr emitted
2.7 lbs/hr(hr/40.6 MMBtu)=0.066 lb/MMBtu
The combined fuel oil emissions of all boilers(sans the temporary boilers)are less than the limit for a single
boiler. The AP-42 particulate factor for natural gas is 0.007 lb/MMBtu. Perdue is assumed in compliance
with 2D.0503.
2D.0515 "Particulates from Miscellaneous Industrial Processes"
This rule applies to the three poultry receiving and handling systems. Assuming each bird weighs a minimum
of one pound,allowable emissions are:
P<30 tons/hr E=4.10 x 200.67
E=32.42 lbs/hr
For the receiving baghouses, Perdue bases emissions on a factor of 0.0003 lbs per bird processed. The factor
is based upon the weight of the amount of particulate(feathers and dust)collected over one day of processing
divided by a total of 16 hours of production per day.
40,000 maximum lbs birds/hr x 0.0003 lbs/bird processed x(1-.999)percent control eff. =0.012 lbs/hr
The facility should comply with the rule as long as the baghouses are maintained. They perform weekly
maintenance external inspections and quarterly internal inspections of the baghouses. I reviewed all the
records for 2014 to current. The quarterly 2014/2015 inspection dates are 3/22/2014, 5/17/2014, 8/16/2014,
11/15/2014,and 3/14/2015. And example of the quarterly inspections is attached to the file copy of this
report.
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213.0515 also applies to the si„rk.,s.The only emission from the singers is .._i propane gas combustion.
0.008 lb/MMBtu(40.6 MMBtu/hr)=0.32 lb/hr
Perdue appears to be in compliance with 2D.0515.
2D.0516 "Sulfur Dioxide Emissions from Combustion Sources"
The regulation applies to the No. 6 fuel oil and natural gas combustion on the boilers,and the diesel
generator. Compliance is assumed since their February shipment fuel certification indicates a sulfur content
of 0.47%by weight. Natural gas and propane contain negligible sulfur. Perdue is in compliance with
2D.0516.
2D.0521 "Control of Visible Emissions"
This rule applies to all sources.No visible emissions violation has historically been recorded for this facility.
All of the sources' visible emissions were observed to be 0%during the inspection. Perdue is assumed in
compliance with 2D.0521.
2D.0535 "Excess Emissions Reporting and Malfunctions"
Perdue is required to report excess emissions from deviations or malfunctions that last more than four hours.
None were reported since the last inspection.
2D.0540 "Particulates from Fugitive Non process Dust Emission Sources"
The facility may not generate fugitive dusts that go beyond the property boundary and cause a substantive
complaint. Fugitive emissions are those that don't pass through a stack or vent,and are generated within
plant property boundaries. The primary fugitives from Perdue come from truck traffic. I did not see any
fugitive dust leave the property boundary during the inspection. I did observe dust on-site generated by
chicken truck traffic.
2D.1806 "Control and Prohibition of Odorous Emissions"
Odor is generated by the chicken processing facility primarily at the wastewater treatment system. There are
treatment ponds located between the processing plant and Valley Protein's rendering plant. Both facilities use
the wastewater system,but Perdue is owns and operates it. The rendering plant generates a musty, slightly
bitter"cooked"(my opinion)smell from the process emission sources. The wastewater treatment system
odor is also musty, but has a rotten tinge. Wastewater odors seem more likely to leave the property in warmer
months while operating the aerators. Perdue staff is supposed to pay attention to wind direction before
running the aerators on really hot days. There are residences on the other side of the tree line to the north that
can be affected by wastewater odors.
I did notice odors on and off-site during the inspection. As I approached the plant from the south on Highway
308 about 10:00 am, I smelled cooked odor at the church, which is less than a tenth of mile from the plant.
The odor continued along the highway until just after passing the plant. The cooked odor was very strong at
approximately 12:00 pm when we physically inspected Perdue's emergency generators,which are near the
anaerobic pond and close to the rendering plant. At that time I noted there was a steady wind from the west
and the temperature was 71°F(see the weatherunderground.com data attached to the file copy of this report).
There was an odor in the receiving yard similar to a chicken house odor during the inspection. There were
many loaded trucks(live chickens)waiting in the yard under open hangers with fans blowing on the chickens.
The large aerators and the tube aerators in the equalization basin were in operation during the inspection.
The wastewater system did not generate odor for most of the inspection,but I did smell it around 12:33 pm
when I completed the inspection. I was standing right next to the aeration pond, and it did not appear to carry
far from the pond. I performed odor surveillance along Highway 308 from Lewiston to Kelford from 12:40-
12:50 pm. The same cooked odor was detected at the nearby church(which is east of the facilities).
There are two openings to the stormwater drain located along the left edge of the loading yard and about 50
feet from the wastewater pond. Wash water from trucks go to the second drain, and some of the water can
stagnate in the drain. The odor can be very strong, but I did not smell it during this inspection. I smelled it
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during last year's inspection, nut the odor did not carry further than 20-36 feet from the drain openings. Joey
noted again that he has never smelled it off-site. I believe a decent wind could mix this odor with the
wastewater and rendering odors.
I performed another odor surveillance from Highway 308,and along the plant road on 3/19/2015,while
conducting an annual inspection at W.E.Partners 11. I did not observe any odor from Perdue.
The legislature has passed rules that require agricultural related complaints and enforcement be kept
confidential. Agricultural operations have not yet been defined under the legislation, so for now the
chicken processing facility is to be considered an agricultural operation. Therefore,any documentation of
complaints received by DAQ concerning Perdue must be stored in the WaRO confidential cabinet.
2Q.031 S "Synthetic Minor Facilities"
To avoid Title V permitting, Perdue limited criteria pollutant emissions to less than 100 tpy each(SOZ and
NOx are the limiting pollutants). The facility is inherently small for HAP emissions. Permit Specific
Condition No. 12 requires Perdue to track monthly fuel usage and calculate monthly emissions of SOZ and
NOx. I reviewed their fuel usage records,and they were complete. Perdue is required to submit an
annual report of fuel usage and rolling 12-month emissions of SOZ and NOx over the calendar year. The
reports have been on time,complete and in compliance.
2Q.0317 "Avoidance Conditions"(of Prevention of Signification Deterioration)
To avoid PSD permitting, Specific Condition No. 13. requires Perdue to meet the recordkeeping and reporting
requirements Permit Condition No. 12. For 2Q.0315.
112R Risk Management Plans
112R applies for ammonia use in Perdue's refrigeration system at the processing facility. DAQ I I2R
inspections are on a 4-5 cycle. The most recent inspection was conducted by Alicia Mangum and me on
3/30/2012. All of the elements listed on our inspection form appeared to be met by Perdue. The elements of
112r are incorporated into the facility's overall PSM library.
The results of the 112R inspection were recorded on separate forms that are kept in a logbook for all 112R
inspections done by WARO(Robert Bright keeps the book). A copy of the forms was sent to Mike Reid at
DAQ Central Office.
There have been no significant changes to their PSM program since the last 112R inspection. No new
equipment has been installed.
When Perdue sold the rendering plant to Valley, it received a new permit and premise number for the
chicken processing plant. It gives the appearance that facility 0800109 has never had a112R inspection
because all of the records are associated with Valley's facility ID 0800081. To remedy the
confusion,WaRO has entered a full I I2R inspection in the Actions Inspections IBEAM database in
association with this inspection. This is only a placeholder representing the 3/30/2012 112R inspection.
Subpart JJJJJJ-NESHAP for Boiler Area Sources
This facility is a minor source of HAPs,but the Area Source Boiler GACT applies to their boilers. The
boilers are all greater than 10 MMBtu/hr and burn fuel oil only during natural gas curtailment. The
boilers are considered existing sources under the regulation. Because they only burn oil during
curtailment,the boilers can be exempted from the regulation as natural gas boilers. However,Perdue
wishes to retain the opportunity to switch to oil outside of curtailment. Perdue submitted the initial
notification for the boilers on 9/20/2011.
The boilers must be tuned every two years. The following must be performed to meet the tune-up
requirement:
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• As applicable, inspect the uu,ner,and clean or replace any component.—the burner as necessary(the
Permittee may delay the burner inspection until the next scheduled unit shutdown,but must inspect
each burner at least once every 36 months).
• Inspect the flame pattern,as applicable,and adjust the burner as necessary to optimize the flame
pattern. The adjustment should be consistent with the manufacturer's specifications, if available.
• Inspect the system controlling the air-to-fuel ratio, as applicable, and ensure that it is correctly
calibrated and functioning properly.
• Optimize total emissions of carbon monoxide.This optimization should be consistent with the
manufacturer's specifications, if available.
• Measure the concentrations in the effluent stream of carbon monoxide in parts per million, by
volume, and oxygen in volume percent,before and after the adjustments are made(measurements
may be either on a dry or wet basis, as long as it is the same basis before and after the adjustments are
made).
• Maintain onsite a biennial report(see item c. below)containing the concentrations of CO in the
effluent stream in parts per million,by volume, and oxygen in volume percent, a description of any
corrective actions taken,and the type and amount of fuel used over the 12 months prior to the biennial
tune-up.
Perdue's official initial tune-ups on the boilers were conducted on 1/26/2014(the reports are in the WaRO
file). However,C&C performs monthly tune-ups on the boilers. I have looked at their records, and the
monthly tune-ups may meet the requirements under the GACT. The latest ones were conducted on
2/18/2015 and 1/7/2015.
Perdue has also completed energy assessments for the boilers. A copy of the energy assessment results is
in the DAQ file. Perdue submitted the Notice of Compliance Status report required by Subpart 6J to EPA
CDX/CEDRI and DAQ on 5/08/2014.
ES-4 and ES-5 have daily,weekly and monthly PM routes.There have been no boiler malfunctions since
last inspection. When there is a malfunction,a work order is generated out of the Maximo maintenance
system.
Subpart ZZZZ-NESIIAP for Stationary Reciprocating Internal Combustion Engines
The engines are considered existing because they were installed prior to June 12, 2006. Perdue submitted
the initial notification for the two diesel generators(2628 hp each)on 1/25/2012.They were previously
categorized as peak shaving,and were granted a compliance extension to May 3,2014. However,Perdue
made a decision to operate these engines only for emergencies. The engines are listed as emergency/peak
shaving on the permit,and permit con3i-f:i n_To._A:I—. 4--s�o peak shavers, so changes need to be made in
the next permit modification or renewal. — - -
We read the hour meters on each engine. Engine 22A read at 996 cumulative hours, and 22B read at 782
cumulative hours. Perdue has recorded the hours operated each time they start up the engines. Neither
engine was operated more than 8 hours in 2014 for maintenance and readiness testing. There were no
hours in 2014 where the engines were operated for emergency purposes.
Maintenance and Work Practices
• Change oil and filter every 500 hours of operation or annually,whichever comes first.
• Inspect air cleaner every 1,000 hours of operation or annually,whichever comes first, and replace as
necessary.
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• Inspect all hoses and belts every 500 hours of operation or annually, wntchever comes first, and
replace as necessary.
• Operate and maintain the engine and control device(if there is one)according to the manufacturer's
emission related written instructions or your employer's plan that minimizes emissions from the
engine to the extent practicable.
• Install a non-resettable hour meter.
• Minimize the engine's time spent at idle during startup and minimize the engine's startup time to a
period needed for appropriate and safe loading of the engine,not to exceed 30 minutes.
Enaine Operation
There is no time limit on use in emergency situations. Each emergency engine may be operated up to 100
hours per year for maintenance checks and readiness testing, provided that the tests are recommended by
federal, state or local government, the manufacturer, the vendor, the regional transmission authority or
equivalent balancing authority and transmission operator, or the insurance company associated with the
engine.
Recordkeeping—Keep the following records for at least five(5)years showing:
• the engine was operated and maintained according to the manufacturer's emission related operation
and maintenance instructions or the Permittee's maintenance plan which must provide for the
maintenance and operation of the engine in a manner consistent with good air pollution control
practice for minimizing emissions. This includes keeping records of maintenance requirements listed
above(oil and filter changes,air cleaner and hose inspections).
During 2014 one of the engines was shipped out for refurbishment from February to June. They plan
to send the other engine for refurbishment this year. Maintenance/testing is done monthly by Perdue.
The Maximo system was down during the inspection, so we could not access the records for
maintenance. We did look through some paper records for several months instead. The most recent
readiness test and maintenance inspection were on 3/10/2015.
One of the engines met the maintenance and work practice requirements above when it went back to
the manufacturer for refurbishment. The other engine only appeared to have specific record of hose
and belt replacement/repair. However, Gregory Poole had been onsite to conduct maintenance on
4/23/2014, 7/16/2014, and 8/07/2014. Their maintenance manager agreed to keep a more specific
record of when oil/filter was changed, and when the air cleaner and hoses/belts are inspected.
• the hours of operation of the engine that is recorded through the non-resettable hour meter. Document
how many hours are spent for emergency operation vs.hours for maintenance and testing(date, start
time and end time of the engine operation for these purposes). I looked through the operator's logs of
hours they recorded from the engine meters. The records were complete
Monitoring,Recordkeeping and Reporting(MRR)
All permit-required records were reviewed for calendar year 2014 to February 2015. There was a minor
issue with fully documenting completion of Subpart ZZZZ maintenance and work practice records. However,
the records did not appear to be a compliance issue. Perdue's reports have been submitted on time and are
complete. The MRR requirements are listed in the table below.
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Monitoring/Record keeping Requirement Monitoring/Recordkeeping Regulation Report Required
Frequency
Nat gas/fuel oil used in ES-4 and ES-5 Monthly 2Q.0315 and Annual report of the monthly
213.0317 fuel amts and 12-month rolling
totals
Calculate boiler SO2 and NOx emissions Monthly 2Q.0315 and Annual report of monthly and
(<100TPY) 213.0317 12-month rolling emissions
Receiving bagfilters I&M inspections semi-annual internal 213.0515 ---
inspection/maintenance logbooks
ZZZZ requirements effective May 2014. Oil change and inspections,hours 2D.1111 ---
of use emergency vs.testing, GACT ZZZZ
maintenance plan.
Fuel use that Perdue reports to DAQ is based on gas company sales that are routed through Perdue's accounting
department in Salisbury.
Z Perdue actually does weekly external and quarterly internal inspections on the receiving bagfilters. The
baghouses are cleaned out and the shakers are tested.
3 See discussion in Regulatory Review Section about Subpart ZZZZ.
Enforcement History
Perdue sold the rendering plant to Valley Proteins in October 2012. A new premise and permit number
were assigned to Perdue. A new compliance history is established with the new permit. No NOD or NOV
has been issued to the facility.
Comments/Conclusions
Perdue appeared to be in compliance with the permit conditions at the time of the inspection.
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