AQ_F_0800109_20170331_CMPL_InspRpt

C
NORTH CAROLINA DIVISION OF Washingtc !gional Office
AIR QUALITY Perdue Foods LLC-Lewiston
NC Facility ID 0800109
Inspection Report County/FIPS: Bertie/015
Date: 03/31/2017
Facility Data Permit Data
Perdue Foods LLC - Lewiston Permit 10265/R02
3569 Governors Road Issued 4/16/2015
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
NAICS: 311615/Poultry Processing Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP/112r
Ashton Weller Wayne Black W Tim Mizelle MACT Part 63: Subpart ZZZZ
Environmental Director Perdue Agribusiness Environmental Manager
Technician Environmental [phone]
[phone] [phone]
Compliance Data
Comments: The facility appeared to comply with the permit conditions at the ,
time of the inspection. Inspection Date 03/29/2017
Inspector's Name Betsy Huddleston
Inspector's Signature: ✓ Operating Status Operating,
Compliance Code Compliancq- inspection
Action Code FCE
Date of Signature: Y10312,0 J 7 On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
No emissions inventory on record.The emissions inventory is due 07/02/2017.
* Highest HAP Emitted(inpounds)
Five Year Violation History: None
Performed Stack Tests since last FCE:None
Directions
Perdue Foods operates a chicken processing plant located on Highway 308 West in Lewiston Woodville.
Directions from the Washington Regional Office are as follows:
• Take Highway 17 N through Williamston 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 of town.
• Turn left and then 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 offices are in two white buildings
on the left, next to the wastewater treatment system. Ashton's and Tim's offices are in the
back building.

1
Safety Concerns
• There are tractor trailers frequently coming and going from the facility, so drive very slow on
the facility grounds.
• The bird receiving area is very active with the trucks and forklifts unloading bird cages.
When walking through the receiving hanger, make eye contact with the drivers.
• Hearing protection,reflective vest, hard hat, safety glasses and safety shoes are required.
Permit History
• 10265R00 was issued on 10/17/2012. Perdue 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 Synthetic Minor permit and new
premise number.
• RO1 was issued on 2/14/2013 for a name change to the facility.
• R02 was issued on 4/16/2015 to add No. 2 fuel oil as a fuel to be combusted in the boilers.
Perdue combusts only ultra-low sulfur(15 ppm)fuel oil.
• The permit will expire 9/30/2017.
Process Description
99,815,583 chickens went through the processing facility in 2016(compared to 98,763,016 head in 2015).
• 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 loading area hoods and room air go 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 to kill bacteria(aparacetic acid, but can also use tri-sodium
phosphate,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.
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Permitted Sources/Inspection ( �rvations
I performed records review and physical inspection of the permitted sources and controls on 3/29/2017. The
inspection was completed with assistance from Ms. Ashton Weller. 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
ES-1 Three(3) live poultry receiving and handling CD-1 ,bagfilters(2,800 square feet of filter
ES-2 systems CD-2 area,each)The units run at about
ES-3 CD-3 18,000 ACFM each. The bagfilters/
ductwork appeared to be in good
shape. They each have a pressure
;gauge. VE from all was 0%.
ES-4 Two(2)natural gas/No.2 fuel oil/No.6 fuel oil-
ES-5 ,fired boilers(20.3 million Btu per hour
(NESHAP) maximum heat input capacity)The boiler
�plates say the heat inputs are 20.9 N/A N/A
MIY[Btu/hr. Both boilers were firing natural
gas during the inspection. ES-4 was on low j
fire. _
ES-22A Two(2)diesel-fired emergency/peak shaving
ES-22B generators(2,628 horsepower engine output) N/A N/A
(NESHAP) The engines were not operating during the
jinspection. They are for emergency use only. j
Natural gas usage for 2016 was 139,143 mcf(usage for 2015 was 141,536 mcf). No. 2 fuel oil was only
combusted in March of 2015 (7,500 gallons). No. 6 oil was only combusted in (3,048 gallons). No. 6
fuel oil is no longer purchased or combusted on-site.
Natural gas usage is metered. Fuel oil shipments are tracked at the plant and by Perdue's accounting
department in Salisbury. Billing statements are kept on file. Perdue purchases ultra-low sulfur No.2 oil
0
(<0.05/o by wt.). There was one fuel oil shipment in CY2016(12/16/2016), and there has been one oil
shipment so far in CY2017(1/17/2017).
The maximum pressure for each boiler is 150 psi. The boilers were constructed in 1975. The boilers
were firing at the following rates during the inspection.
Parameter Boiler ES-4 Boiler ES-5
Steam pressure 113 psi 115.2 psi
Visible emissions 0% 0%
Fuel Natural Gas Natural Gas
Steam 29,450lbs/hr 53,031lbs/hr
Stack temp 261OF 302OF
Oxygen 16.9% 2.7%
Efficiency 84.1% 82.9%
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 external physical condition. These bagfilters have a stainless steel filter
system that provides additional air exchanges in the hanging room and coverage over a larger building
area. It is my understanding the collection barrels are emptied nightly.
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The pressure drop across baghouse CD-1 was 2.5 in. H2O, and the pressure drop across CD-2 was 3.0 in.
H2O. The pressure gauge for CD-3 read 6.0 in. H2O, but Ashton said the gauge has been reading high for
a couple months,even after they performed a cleanout of the baghouses on 2/25/2017. They have
inspected the baghouse and it is operating fine. They plan to replace the pressure gauge. No emissions
were observed from the baghouses. The area around the bagfilters was clean.
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)
The exemption regulation cited above will need to be changed in the permit renewal to reflect the changes
to 2Q.0102 that were promulgated in mid-2016.
I did not physically inspect the singers. Ms. Weller confirmed there have been no physical or operational
changes to either the singers or refrigeration system since the last inspection date. All of the emissions
from the singers come solely from propane combustion. 48,844 gallons of propane were combusted in
CY2016(39,691 gallons in 2015).
The only regulation that applies to the refrigeration system is 112R(discussed in the Regulatory Review
below). I did not include a detailed inspection of the system because a 112R compliance inspection of the
system was conducted on 9/30/2015 by Mike Reid(RCO 112R Program Coordinator)and Randall Jones
(WaRO).
Applicable Reimlations/Reiulatory Review
2D.0202 "Registration of Air Pollution Sources"
Specific Condition A.2.
The Director has the authority to require submittal of information about air pollution sources, and to
require registration of those sources. It is under this Rule that the Division is requiring facilities to submit
an emissions inventory 90 days before a Permit expires. The permit will expire 9/30/2017. Ashton
Weller and I discussed their upcoming renewal and she is aware of these deadlines.
2D.0503 "Particulates from Fuel Burning Indirect Heat Exchangers"
Specific Condition A.3.
The boilers have never been tested for particulate. ES-4 and ES-5 each have an emission limit of 0.42
lb/MMBtu. Worst case emissions are from residual fuel oil combustion,but Perdue does not plan to ever
burn No. 6 oil again. The total estimated emissions using AP-42(boilers<100 MMBtu/hr, worst case
assuming all No. 2 oil use)are as follows:
40,600,000 Btu/hr(gallon/140,000 Btu)(3.3 lb/1000 gallons)=0.95 lbs/hr emitted
0.95 lbs/hr(hr/40.6 MMBtu)=0.023 lb/MMBtu
The combined fuel oil particulate emission of both boilers is less than the limit for a single boiler. The AP-42
particulate factor for natural gas is 0.007 lb/MMBtu.
There are no monitoring, recordkeeping or reporting conditions in the permit for this rule. Perdue is
assumed in compliance with 2D.0503.
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2D.0515 "Particulates from Mis_-___ineous Industrial Processes"
Specific Condition A.4.
This rule applies to the three poultry receiving and handling systems and the singers. Assuming each bird
weighs a minimum of one pound, and 40,000 maximum birds/hr,the combined allowable emission is:
P <_ 30 tons/hr E=4.10 x 200.6'
E=30.51 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.
The only emission from the singers is from propane gas combustion(AP-42 factor).
0.008 lb/MMBtu(40.6 MMBtu/hr)=0.32 lb/hr
There are no monitoring, recordkeeping or reporting conditions in the permit for this rule. Perdue appears
to be in compliance with 2D.0515.
2D.0516 "Sulfur Dioxide Emissions from Combustion Sources"
Specific Condition A.S.
The regulation applies to the fuel oil, natural gas and propane combustion on the boilers, diesel generator and
singers. Compliance is assumed since Perdue has ceased combustion of No. 6 fuel oil, and their No. 2 fuel oil
shipment certifications indicate an ultra-low sulfur content. Natural gas and propane contain negligible
sulfur. There are no monitoring, recordkeeping or reporting conditions in the permit for this rule. Perdue
appears to be in compliance with 2D.0516.
2D.0521 "Control of Visible Emissions"
Specific Condition A.6.
The rule applies to all of Perdue's emissions sources.There is no history of excess visible emissions at this
facility. All of the sources' visible emissions were observed to be 0%during the inspection. There are no
monitoring, recordkeeping or reporting conditions in the permit for this rule. Perdue appears to be in
compliance with 2D.0521.
2D.0535 "Excess Emissions Reporting and Malfunctions"
Specific Condition A.7.
Perdue is required to report excess emissions from deviations or malfunctions that last more than four hours
by 9:00 AM the next business day. No excess emissions have been reported since 11/02/2012 when the CD2
baghouse fan had a shaft/bearing failure. Perdue appears to be in compliance with 2D.0535.
2D.0540 "Particulates from Fugitive Non process Dust Emission Sources"
Specific Condition A.8.
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
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chicken truck traffic. There is no history of dust complaints for this facility in the WaRO file. Perdue
appears to be in compliance with 2D.0540.
2D.0611 "Monitoring Emissions from Other Sources"
Specific Condition A.9.
This Rule requires that the facility maintain records of production rates,throughputs, material usage,and
other process operational information to determine compliance with the facility's permit and all
applicable requirements. Control device I&M permit requirements are constructed under this rule.
The condition requires at least one internal inspection of each bagfilter system each year. The internal
inspections need to be spaced out every 12 months. The condition also requires periodic inspections and
maintenance as recommended by the equipment manufacturer. The results of inspections and records of
any repairs must be recorded in a log.
I reviewed the bagfilter records from March 2016 to current. Perdue performs weekly maintenance routes and
has continued to contract Eastern Environmental to perform quarterly internal inspections. The quarterly
inspections were conducted 6/11/2016, 8/27/2016, 11/19/2016 and 2/25/2017. I did not see any record of bag
changeouts in the last year.
Perdue appears to be in compliance with 2D.0611.
2D.1111 "Maximum Achievable Control Technology"
Subpart JJJJJJ-NESHAP for Boiler Area Sources
Specific Condition No.A.10.
This facility is a minor source of HAPs,but the Area Source Boiler GACT applies to their boilers. The
boilers are greater than 10 MMBtu/hr. The boilers are considered existing sources under the regulation.
They usually burn fuel oil only during natural gas curtailment. The gas company informs the facility of
curtailment with a phone call (or occasional email). Because Perdue burns oil only during curtailment,
Perdue could choose to exempt the boilers from the regulation requirements by declaring them as natural
gas boilers. However, Perdue wished to retain the opportunity to switch to oil outside of curtailment. If
they decide to claim the exemption in the future, WaRO will need to remind them to create records of gas
company curtailment notifications.
The initial notification was submitted to DAQ on 9/20/2011. Perdue submitted a Notice of Compliance
Status report required by Subpart 6J to DAQ on 12/05/2012, and again to EPA CDX/CEDRI and DAQ on
5/08/2014.
The boilers must be tuned every two years. The following must be performed to meet the tune-up
requirement:
• Asa applicable, inspect the burner, and clean or replace any components of the burner as necessary(the
PP , p p
facility 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.
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• 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 containing the concentrations of CO in the effluent stream in parts
per million, by volume, and oxygen in volume percent, measured at high fire or typical operating
load, before and after the tune-up of the boiler, 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 has tune-ups that meet the requirements conducted annually. They have contracted with C&C
Boiler. The most recent 6J tune-ups were completed on I I/16/2015 and 11/15/2016. The 2016 tune-up
records are attached to the file copy of this report.
Perdue has completed the required energy assessments for the boilers(dated 3/06/2014,due 3/21/2014).
A copy of the energy assessment document is in the DAQ file.
ES-4 and ES-5 have daily,weekly and monthly PM routes. When there is a malfunction, a work order is
generated out of the Maximo maintenance system.
Perdue is required to keep records of monthly fuel usage. The records were on file and Perdue reports
fuel usage to DAQ annually under 2Q.0315.
The regulation requires Perdue to prepare a`Biennial Compliance Report' by March 1 of every other year
starting March 1, 2015. If there are no deviations to record,the report can stay on file at the facility, and
be supplied at DAQ's request. If there are deviations,the report must be submitted to DAQ by March
15`h. The report must include the items listed under 40 CFR 63.11225(b)(1-2). Perdue is generating a
compliance report annually. Copies of the March 2016 and March 2017 reports are attached to the file
copy of this report.
Perdue appears to be in compliance with 2D.1111 and NESHAP Subpart 6J.
2D.1806 "Control and Prohibition of Odorous Emissions"
Specific Condition No.A.11.
Condition A.11. states that Perdue shall not operate the facility without implementing management practices
or installing and operating odor control equipment sufficient to prevent odorous emissions from the facility
from causing or contributing to objectionable odors beyond the facility's boundary
Odor is generated by the chicken processing facility primarily at the open 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 owns and operates it.
The rendering plant raw material delivery/storage and meal/grease process equipment are regulated by
2D.0539 for odor. The Perdue chicken processing facility is not regulated by 2D.0539. 2D.1806 exempts
processes at facilities that produce feed-grade animal proteins or feed-grade animal fats and oils.
However,the wastewater treatment system is not considered part of the production processes at the
rendering plant. Therefore, for the combined Perdue/Valley Proteins wastewater treatment system, I
believe 2D.1806 does apply.
Wastewater odors are more likely to leave the property in warmer months while operating the aerators.
Perdue staff are supposed to pay attention to wind direction before running the aerators on really hot days, so
as to be considerate of residences on the other side of the tree line to the north.
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I checked with Robbie Bullock, WaRO's Division of Water Resources inspector for Perdue, about the results
of the last compliance inspection at the facility. It was conducted on 7/26/2016 and the wastewater treatment
system was found in compliance with the conditions of the permit.
The rendering plant can generate a musty, slightly bitter"cooked"smell from the process emission sources.
A rotten/decomposing odor can come from the wastewater aeration pond. I have never smelled any definitive
odor from the settling pond. For this inspection I did not smell any odors as I approached the plant from the
south on Highway 308 about 9:30 AM(the wind direction during the inspection was from the north, and the
temperature was about 58°F). During the inspection at about 10:10 AM, while I was standing next to the
aerator pond, I did smell odor. However, it did not appear to carry much further than the ten feet from the
pond. When I completed the inspection I performed surveillance(starting at 11:10 AM)on Hwy 308 north
through Kelford and along Black Jack Road for 5 miles. I also performed surveillance back through Lewiston
on Hwy 308. The wind direction was from the north and the temperature was 63°F. I did not observe any
odor. Perdue appeared to be compliant with the rule during the inspection.
There were loaded trucks(live chickens)waiting in the yard under open hangers. Rendering material was
loading into the top of an open trailer. There was a slight `livestock' odor in the yard area.
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 believe a
decent wind could mix this odor with the wastewater and rendering odors.
Ms. Weller said Perdue had not received any complaint since DAQ performed the March 2016 inspection.
When a complaint is made to DAQ, I contact and/or visit both Perdue and Valley Proteins. I ask Perdue to
scrutinize their operations for any malfunctions, imbalances,or unexpected changes in operation,and to
quickly perform any corrections or repairs.
1 received a comment from an individual (who wished to remain anonymous)who attended a county
commissioners meeting in Kelford the evening of 10/24/2016 that they smelled a very strong rotted odor near
Perdue as they travelled to attend the meeting. They did not wish for DAQ to log a complaint. I wrote a
memo of the call instead.
Because of the nature of the odor description, I contacted Joey Baggett at Perdue first, rather than Mike
Anderson at Valley Proteins. Joey responded by email on 10/26/2016. The email noted that the pump for the
trailer wash had failed over the weekend and wash water had ponded instead of being pumped to the WWTS.
Based on his conversation with plant personnel,but he believes that any odor on 10/24 would have come
from the ponding. The truck wash is beside the back guard gate where I come in for inspections. This is a
rather open area along the road and not far from Highway 308.
2Q.0315 "Synthetic Minor Facilities"
Specific Condition No.A.12.
To avoid Title V permitting, Perdue limited criteria pollutant emissions to less than 100 tpy each(SO2 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 SO2 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 SO2 and NOx over the calendar year. The
reports have been on time, complete and in compliance. Perdue is in compliance with 2Q.0315.
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2Q.0317"Avoidance Conditions , f Prevention of Signification Deteriorat
Specifrc Condition No.A.13.
To avoid PSD permitting, Specific Condition No. 13. requires Perdue to meet the recordkeeping and reporting
requirements Permit Condition No. 12. for 2Q.0315.
2D.1111 "Maximum Achievable Control Technology"
Subpart ZZZZ-NESHAP for Stationary Reciprocating Internal Combustion Engines
Specific Condition A.14.
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 condition No. A.14. is written for peak shavers, not emergency engines.
This condition needs to be changed in the next permit modification or renewal to reflect requirements for
emergency engines.
Emergency Engine Maintenance and Work Practice Requirements
• 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.
• Inspect all hoses and belts every 500 hours of operation or annually, whichever comes first, and
replace as necessary.
The annual PM conducted by Gregory Poole on 7/29/2016 satisfied the above requirements.
• Operate and maintain the engines according to the manufacturer's emission related written instructions
or your employer's plan that minimizes emissions from the engine to the extent practicable.
Perdue follows the manufacturer maintenance manual.
• Install non-resettable hour meters.
Ashton Weller is with maintenance staff during monthly I&M activities, and she records the hours
operated.
• Minimize the engine 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.
Perdue did not use these engines during Hurricane Matthew. They rented portable engines instead. They
ended up using none of the engines because they never lost power during or after the hurricane.
Emergency Engine Operation Requirements
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. ES22A operated at total of 6 hours in CY2016. ES22B operated 5 hours in CY2016.
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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).
Perdue follows the manufacturer's operating manual.
• 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 reviewed Perdue's records, and they
are complete.
Perdue appears to be in compliance with 2D.1111 and NESHAP Subpart ZZZZ,
2D.2100 "Risk Management Program"
Clean Air Act Section 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-year cycle. The most recent inspection was conducted on 9/30/2015 by Mike
Reid(RCO 112R Program Coordinator)and Randall Jones(WaRO). Their inspection report is in
Documents Module in IBEAM and stored on the WaRO LAN at g:\AQ\Shared\Bertie08\00109\2015-09-
30 Lewiston RMP Insp Report.doc. They found that Perdue appeared to address all of the required
elements in the Risk Management Program.
The elements of 112r are incorporated into the facility's overall PSM library. 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. 11,013 lbs
were purchased/emitted in 2016 (compared to 10,006 lbs of ammonia purchased/emitted in 2015).
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 had never had al 12R inspection
because all of the records are associated with Valley's facility ID 0800081. To remedy the confusion,
WaRO entered a full I I2R inspection in the Actions Inspections IBEAM as a placeholder for the
3/30/2012 112R inspection. The 9/30/2015 inspection has its own record in IBEAM Inspections apart
from the annual permit compliance inspection.
Monitoring,Recordkeeping and Reporting(MRR)
All permit-required records were reviewed for March 2016 to current. No problems were observed. Perdue
retains all permit required records for at least a decade. Perdue's reports have been submitted on time and are
complete. The MRR requirements are summarized in the table below.
Mon itorin /Reco rdkeeping Requirement Frequency Regulation Report Required
Nat gas/fuel oil used in ES-4 and ES-5 ' Monthly 2Q.0315 and 2D.0317 Annual report of monthly
2D.I I I I (6J) amts and 12-month rolling totals
Calculate boiler S02 and NOx emissions(<100TPY) Monthly 2Q.0315 and 213.0317 Annual report of monthly and
12-month rolling emissions
Receiving bagfilters I&M internal inspections2 Annual 213.0611 ---
Receiving ba filters inspection/maintenance logbooks Continuous 2D.0611 ---
Boiler tuneu s'and compliance certification report Biennially 2D.I I I I (6J) Kept on-site
Engine oil change and inspections Annual 21).1111 (ZZZZ) ---
Engine recording hours of emergency vs. I&M use, Continuous 213.1 111 (ZZZZ) ---
maintenance plan.
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' Fuel use that Perdue reports to I is based on gas company sales that are route, c)ugh Perdue's accounting
department in Salisbury.
2 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 Subparts JJJJJJ and ZZZZ.
Enforcement History
No NOD or NOV has been issued to the facility since issuance of the new permit in October of 2012.
Comments/Conclusions
Perdue appeared to be in compliance with the permit conditions at the time of the inspection.
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