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HomeMy WebLinkAboutAQ_F_0800109_20220113_CMPL_InspRpt NORTH CAROLINA DIVISION OF Washington Regional Office AIR QUALITY Perdue Foods LLC-Lewiston NC Facility ID 0800109 Inspection Report County/FIPS:Bertie/015 Date: 04/20/2022 Facility Data Permit Data Perdue Foods LLC-Lewiston Permit 10265/R03 3569 Governors Road Issued 8/25/2017 Lewiston Woodville,NC 27849 Expires 7/31/2025 Lat: 36d 8.6751m Long: 77d 12.8460m Class/Status Small 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 Tim Mizelle Virgil Mitchell Ashton Weller MACT Part 63: Subpart 6J Environmental Manager Director of Operations Wastewater Manager (252)348-4291 (252)344-0414 (252)348-4390 office (252)287-2427 cell Compliance Data Comments: The facility appeared to be operating in compliance with all applicable Federal and State rules,regulations and permit conditions at the time of the Inspection Date 01/13/2022 inspection. Inspector's Name Andrew Langley Operating Status Operating Compliance Code Compliance-inspection Inspector's Signature:,4wdrew "VLOl,eu Action Code FCE On-Site Inspection Result Compliance Date of Signature: 04/20/22 Total Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PM10 *HAP 2016 0.0500 0.0400 7.65 0.4000 6.10 0.0300 250.00 *Highest HAP Emitted(in ounds) 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, Bertie County. 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. 1 https://ncconnect.sharepoint.com/sites/DAQ-WaRO/FacilitiesBertieO8/00109/0800109 20210113 a16. • Turn left onto Governor's Road 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 into the main yard then turn left onto a short gravel path toward the WWT aeration ponds. The environmental offices are in two white buildings next to the wastewater treatment system. Ashton's and Tim's offices are in the back building. Safety Concerns • There are tractor trailers frequently coming and going from the facility, so drive slowly 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. A face covering is required during the Covid 19 pandemic. Process Description 79,443,902 chickens went through the processing facility up thru November 2021. The facility continues to operate 2 shifts/5 days a week. • 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. Permitted Sources/Inspection Observations I performed records review and physical inspection of the permitted sources and controls at 11:30 a.m. on 01/13/2022. The inspection was completed with assistance from Ashton Weller. The following table contains 2 hgps://ncconnect.sharepoint.com/sites/DAQ-WaRO/Facilities/BertieO8/00109/20210113.a l 6. a summary of all permitted emission sources and associated air pollution control devices. Some observations from the inspection are noted in bold print. Emission FEmission 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 were 0%. ES-4 Two(2)natural gas/No.2 fuel oil-fired boilers ES-5 (20.3 million Btu per hour maximum heat input No VE's were observed during the (NESHAP) capacity)The boiler plates say 20.9 N/A MMBtu/hr. Both boilers fired natural gas inspection. during the inspection. ES-22A Two(2)diesel-fired emergency/peak shaving ES-22B generators(2,628 horsepower engine output) Both of these have been removed from (NESHAP) The engines were not operating.They are for N/A the facility. emergency use only. 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 (<0.0015%by wt.). The last fuel oil shipments fuel oil shipments received by the facility were in CY2017. At the time of this inspection,the Natural gas usage for CY2021 indicated 118,915 Mc£ 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 110.5 psi 114.1 psi Visible emissions 0% 0% Fuel Natural Gas Natural Gas Steam 12,193lbs/hr 4,879lbs/hr Stack temp 3950F 3950F 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. No visible emissions were observed from the baghouses. Ms. Weller told me that Eastern Environmental performs quarterly PM on their baghouses. The area around the bag filters was clean. Pressure gauges are on the baghouses. The following list of insignificant sources is attached to the permit: Source Exemption Due to the Covid 19 restriction Regulation I did not go into the processing IES-6-refrigeration system 2Q .0102(g)(14)(F) area to inspect the signers.Ms. IES-7-propane-fired singers for poultry feathers Weller confirmed there have (4.4 million Btu per hour maximum heat input) 2Q .0102(h)(5) been no physical or operational Wastewater treatment system 2Q.0102(g)(6) changes to either the singers or 3 hgps://ncconnect.sharepoint.com/sites/DAQ-WaRO/Facilities/Bertie08/00109/20210113.a l 6. refrigeration system since the last inspection date. All the emissions from the singers come solely from propane combustion. The only regulation that applies to the refrigeration system is I I2R(discussed in the Regulatory Review below). I did not conduct a full inspection of the system because a 112R compliance inspection will be due in this 5-year cycle. DAQ last conducted a full 112R inspection on 9/30/2015. No state or federal requirements apply directly to the wastewater treatment system, so it is deemed as insignificant. Applicable Regulations/Reimlatory 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 7/31/2025, so they will owe a CY2024 emissions inventory with their permit renewal application. 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. 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. 2D.0515 "Particulates from Miscellaneous 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 200.67 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. According to Ms. Weller, weekly inspections and maintenance are performed in addition to the quarterly PM of the baghouses by Eastern Environmental. 4 hgps://ncconnect.sharepoint.com/sites/DAQ-WaRO/Facilities/BertieO8/00109/20210113.a l 6. 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.5. 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 or malfunctions have been reported since the last FCE. 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 goes 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. Chicken truck traffic could generate mild dust during dry conditions. There is no history of dust complaints for this facility in the I Beam database. 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. Perdue performs weekly maintenance routes and Eastern Environmental performs quarterly internal inspections which count as an annual inspection. I reviewed the weekly inspections and quarterly inspection records for CY2021. The records appeared to be complete. 5 hgps://ncconnect.sharepoint.com/sites/DAQ-WaRO/Facilities/BertieO8/00109/20210113.a l 6. 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,and 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 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 boilers must be tuned every two years. The following must be performed to meet the tune-up requirement: • As applicable, inspect the burner, and clean or replace any components of the burner as necessary(the 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. • 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 conducts annual tune-ups that meet the requirements. They have contracted with C&C Boiler. 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. 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'. The report must include the items listed under 40 CFR 63.11225(b)(1-2). Perdue is generating a compliance report annually. 6 hgps://ncconnect.sharepoint.com/sites/DAQ-WaRO/Facilities/BertieO8/00109/20210113.a l 6. Both Boilers were operating at the time of the inspection.No Visible Emissions were noted coming from the stacks. Perdue appears to be in compliance with 21).1111 and NESHAP Subpart 6J. 2D.1111 "Maximum Achievable Control Technology" Subpart ZZZZ-NESHAP for Stationary Reciprocating Internal Combustion Engines Specific Condition A.H. The 2 engines were sold in November of 2019 and removed from the property. 21).1806 "Control and Prohibition of Odorous Emissions" Specific Condition No.A.12. Condition A.12. 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. Ms. Weller said Perdue had not received any odor complaints since the last inspection and I did not detect any odors outside of the facility at the time of the inspection. Perdue appears to be in compliance with 2D.2100 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 112R inspections are on a 5-year cycle. Perdue is due for a 112R inspection in the next 5-year cycle. "General Conditions and Limitations." The facility appeared to be in compliance with all General Conditions and Limitations at the time of the inspection. Enforcement History No NOD or NOV has been issued to the facility in the last five years. Comments/Conclusions Perdue appeared to be in compliance with applicable Federal and State air quality rules,regulations and permit conditions at the time of the inspection. 7 hgps://ncconnect.sharepoint.com/sites/DAQ-WaRO/Facilities/Bertie08/00109/20210113.a l 6.