HomeMy WebLinkAboutAQ_F_0800081_20220920_CMPL_InspRpt (4) NORTH CAROLINA DIVISION OF Washington Regional Office
AIR QUALITY Darling Ingredients Inc. -Lewiston
NC Facility ID 0800081
Inspection Report County/FIPS:Bertie/015
Date: 09/21/2022
Facility Data Permit Data
Darling Ingredients Inc. -Lewiston Permit 03085/T33
222 Griffins Quarter Road Issued 9/16/2022
Lewiston-Woodville,NC 27849 Expires 12/31/2022
Lat: 36d 8.4040m Long: 77d 13.4680m Class/Status Title V
SIC: 2048/Prepared Feeds Nec Permit Status Active
NAILS: 311119/Other Animal Food Manufacturing Current Permit Application(s)TV-Renewal
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP/Title V
Meagan Schulenberg Shane McKinney Matt Haynes MACT Part 63: Subpart 6J
Environmental Manager General Manager Mgr.of Env.Affairs,US
(252)377-5513 (540)877-2092 East
(504)877-2092
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 09/20/2022
inspection. Inspector's Name Kurt Tidd
Operating Status Operating
Compliance Status Compliance-inspection
Inspector's Signature: Action Code FCE
Inspection Result Compliance
Date of Signature: 09/22/2022
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 * HAP
2021 1.01 0.0500 8.12 29.14 6.82 0.9600 292.28
2020 0.5130 0.0500 8.53 26.93 7.16 0.4630 307.04
2019 0.4000 0.0300 5.92 22.29 4.97 0.3600 212.98
*Highest HAP Emitted(in pounds
Five Year Violation History:None
Performed Stack Tests since last FCE:None
Directions
Darlings Ingredients, Inc. operates a chicken rendering plant located on Highway 308 West, Lewiston
Woodville,Bertie County. Directions from Washington Regional Office are as follows:
• Follow Hwy 17 N to Windsor and go through the first stoplight(funeral home on the right).
• At the third stoplight,turn left onto Highway 308 West.
• Stay on Highway 308 to Lewiston Woodville. The plant is located behind the Perdue chicken
processing plant which is on the left side of the road just north of the town.
• Turn left at the Perdue chicken plant and continue down the road past Perdue.
• There is a W.E. Partners facility at the entrance to the rendering plant, so drive past it and go
to the brick office building.
Safety Concerns
• There are trip and slip hazards. The floor is wet, and there are eye and floor level equipment.
• There are tractor trailers frequently coming and going from the facility.
• Hearing protection,hard hat, safety glasses and safety shoes are required.
Permit History
The 5-yr permitting history for the rendering plant is provided as follows:
• T32 was issued on 01/29/2018 for permit renewal. The truck load processing time limits were
updated in this permit revision per Session Law 2015-263.
• A tax certification was issued on 04/09/2018 for replacement of the framing for both the
crossflow and packed bed scrubbers.
• A tax certification was issued on 5/17/2019 for a new 66" Scrubber Fan. This was Darlings
Ingredients' third tax certification for the Lewiston facility.
• T33 was issued on 09/16/2022 to change the name of the facility from Valley Proteins to Darling
Ingredients, Inc—Lewiston.
Process Description
1. Meat/feather trucks dump at the receiving pad. There are three raw material bays(two are for meat
and one is for feathers). There is also a grease hopper that is used for recycling tank bottoms
(cleanout). The material is carried by conveyor and trash is removed. Bone is delivered in
refrigerated trucks. Bone waste is metered into the meat mix. Grease and blood are delivered and
unloaded from enclosed containers.
2. Blood is pumped to holding tanks. It is then sent to two centrifuges, cooked and added to the feathers
before going to the dryer.
3. Trailers are rinsed and sanitized. Time cards are punched when the trucks come onto the property
and again when the trucks are dumped. Timecards are also kept for bone,grease and blood loads.
4. The meat goes to the preheater or bypasses to the dual cooker. Most of the steam is usually provided
by the W.E. Partners boilers (Facility ID 0800107).
5. Meat is discharged from the preheater over a set of drainers to remove excess liquids (fat). The
drainer is hooded and ties into the press vent. The press and preheater vents are low pressure, so they
tie together and vent directly to the venturi scrubber and packed scrubber.
6. Liquid/fat goes to the evaporators. Waste heat from the cookers, feather dryer,hydrolyzer flash and
chamber is used to heat the evaporators. There is an emergency vent on the evaporators. The fat
moisture level is reduced by about half,and then the liquid concentrate is pumped to the meat
cookers.
7. Meat conveys from the preheater to either cooker,but the#2 cooker does not require the use of the
preheater.
8. The cookers discharge into a set of drainers where fat is drained off and pumped over a screening
system. The fat is then pumped to a centrifuge to remove remaining particles. The solids from the fat
are conveyed back to the presses and then cookers.
9. The fat is lastly pumped to centrifuge and holding tanks for shipment.
10. The meat from the cookers goes to four meat presses.All meat is pressed down to a low percentage of
fat. The fat from the press goes back to the screen and centrifuge.
11. Presses#1 and#3 feed to a bin and then a grinder. Presses#2 and#4 also feed to a bin and grinder.
12. The meat(meal)goes through shakers and is conveyed to screens for sizing. It is then transferred to
silos for shipment. Oversized material from the screens is sent back to the grinders.
13. Feathers are processed separately from the meat product. They are transferred from the dump pad to
the hydrolyzer where they break down under pressure. They have a wet oatmeal appearance.
14. The feathers then go through a press where moisture is reduced by more than half. Blood is
centrifuged into a solid, and is metered into the feathers. The feathers are discharged into a flash
chamber,then to a blue-colored cooker(dryer)that is located between the two meat cookers.
Feathers are dried to very low moisture content. The hydrolyzer and feather cooker do not produce as
much condensate as the meat cookers.
15. The feather meal goes to a shaker screen and grinder that is located with the meat grinders. The
feather meal is then transferred to silos.
16. The cookers,hydrolyzer, flash chamber, and feather dryer all vent to the waste heat system before
venting to the venturi scrubber. The press and preheater emissions vent directly to the venturi
scrubber. From there all process emissions go to the packed scrubber. Process room air is pulled
under vacuum to a crossflow scrubber on the roof of the facility.
17. The meal loadout is located in a 3-sided building. Meal is sold to animal feed companies. Fat is sold
for re-blending in feed and as an ingredient in products such as cosmetics. Some nutrient additives are
applied during the rendering process according to client specification.
The plant operates six days a week and on Sundays if there are overflow loads or backlogged loads.
Most of the meat and feathers are supplied by the Perdue processing facility next door,but they do
receive loads from other facilities each day. Sanderson Kinston is another large supplier. They are
now processing Butterball turkey rendering in cooker No. 2. Cooker No. 1 processes only chicken.
Cooker No.1 operates 24/7,but Cooker No.2 starts up in the very early hours of the morning and has
3-4 hours of downtime at the end of each day. Feathers are processed approximately 20-21 hours
each day.
The sources and control devices at the facility are listed on the permit in the following format.
Emission Control
Source ID No. Emission Source Description Device Control Device Description
ID No.
ES-8 and Two natural gas/saleable CD-10F One packed bed scrubber(288 to 575 gallon
ES-9 animal fat/No. 6 fuel oil-fired per minute normal operating range)utilizing
boilers(84 MMBtu/hr max water, air, and filter media to reduce PM and
GACT, heat input capacity, each) SO2 emissions in the boilers and also used
Subpart 6J conditionally for additional control of
noncondensibles depending on fuel fired in
the boilers for the poultry processing
equipment
ES-23 and Two natural gas-fired NA NA
ES-24 temporary,back-up boilers
(less than 90 MMBtu/hr max
heat input capacity, each)
ES-10A.1* One poultry by-product cooker CD-10E One venturi wet scrubber(voluntary for odor
and one dual-use control state-only requirement)
feather/poultry by-product
cooker(ID No. ES-10A.1), Or
ES-10A.2*, and One feather dryer and one CD-lOD One two-stage crossflow wet scrubber(500
hydrolyzer(113 No. ES-10A.2), gallons per minute nominal liquid injection
and rate per stage) and a dry filter mist eliminator
Or
ES-10E* Two liquid/fat evaporators CD-10F One packed bed scrubber(288 to 575 gallon
(ID No. ES-lOE) per minute normal operating range)utilizing
water, air, and filter media to reduce PM and
SO2 emissions in the boilers and also used
conditionally for additional control of
noncondensibles depending on fuel fired in
the boilers for the poultry processing
equipment
Emission Control
Source ID No. Emission Source Description Device Control Device Description
ID No.
ES-1 OB* Poultry by-product presses and CD-IOD One two-stage cross flow wet scrubber(500
preheater(ID No. ES-IOB), gallons per minute nominal liquid injection
and rate per stage) and a dry filter mist eliminator
Or
ES-10D* Process room air collection CD-10F One packed bed scrubber(288 to 575 gallon
(ID No. ES-IOD) per minute normal operating range)utilizing
water, air, and filter media to reduce PM and
SOz emissions in the boilers and also used
conditionally for additional control of
noncondensibles depending on fuel fired in
the boilers for the poultry processing
equipment
The following insignificant sources are listed in the permit attachment. There is one cooling tower that
may eventually need to be added to the list.
ID Number Equipment Description
IES 17 Poultry meal conveyance system
I-WCCS Wastewater collection and conveyance system
IES-11,IES-12,IES-13, Six(6)meal storage silos(ES-11 and ES-14 are 300
IES-14,IES-15, and IES-16 tons capacity and the rest are 100 tons capacity)
IES-19 Meal loadout area(54 tons per hour capacity)
It should be again noted that the cookers,feather dryer,feather hydrolyzer,presses,preheater,and
evaporators are controlled 24/7 by the venturi and packed bed scrubbers. Darlings Ingredients
does not take advantage of the conditional use made available by the permit source table above.
Only the room air vents exhaust to the crossflow scrubber.
Inspection Observations and Regulatory Review
On 09/20/20221 performed a Full Compliance Evaluation(FCE)Of Darling Ingredients,Inc., located in
Lewiston Woodville,NC. The inspection was performed using the current Title V permit(T33). The
inspection was completed with assistance from Matt Haynes,District Environmental Manager. Shane
McKinney, General Manager and Daniel Edward, Safety Manager. I arrived at the facility around 9:00 AM
and met with Mr. McKinney in the main office building,we proceed to the processing building conference
room for the records review portion of the inspection. Mr. Haynes and the facility environmental staff had the
records laid out for my review. I reviewed the records back to January 2021. The only issue I noted in my
records review was that some of the scrubber inspections did not have signatures,Mr. Haynes said he noticed
this when he reviewed the records and the problem had been corrected. No issues were observed with the
sources and the control devices during the inspection. There were no holes or tears observed in the ductwork
or control devices.No Fugitive Emissions observed. There were some odors close to the facility,but I did not
note any while driving up to or around the facility.Mr.Haynes said that they have not received any
complaints in the past 2 years.A search of the I Beam database reveled no complaints. I concluded my
inspection at approximately 10:45 AM.
Two natural gas/saleable animal fats/No. 6 fuel oil-fired boilers (ID Nos. ES-8 and ES-9)
with associated packed tower scrubber (ID No. CD-10F) and two natural gas-fired
temporary, back-up boilers ID Nos. ES-23 and ES-24
Regulated Limits/Standards Applicable Regulation
Pollutant
Particulate matter 0.27 pounds per million Btu heat input(ES-8 and ES-9) 15A NCAC 2D .0503
0.25 pounds per million Btu heat input(ES-23)
0.23 pounds per million Btu heat input(ES-24)
Sulfur dioxide 2.3 pounds per million Btu heat input 15A NCAC 2D .0516
Visible emissions 20 percent opacity 15A NCAC 213 .0521
TSP Less than 41 tons per year combined 15A NCAC 2Q .0317
PM10 Less than 28 tons per year combined (PSD Avoidance)
Sulfur dioxide Less than 215 tons per year combined
VOCs Less than 40 tons per year combined
Carbon monoxide Less than 106 tons per year combined(as aggregate of
Nitrogen oxides all fuel combustion)
Less than 107 tons per year combined
Hazardous air National Emission Standards for Hazardous Air 15A NCAC 2D .I I I I
pollutants Pollutants for Area Sources—Industrial, Commercial, (40 CFR 63, Subpart JJJJJJ)
and Institutional Boilers
W.E. Partners supplies 70-80%of the steam demand at the rendering plant. W.E.Partners is not capable of
making enough steam to supply 100%if Darlings is in full production. Darlings usually operates one of the
boilers(they alternate)to supplement. On a continuous full operation day the steam demand can be as much
as 75,000-80,000 lbs/hr. When it is down,Darlings can operate both of their boilers as needed.
Darlings keeps a temporary boiler on their permit in case something happens to one of the existing
boilers. Darlings owns the temporary boiler and keeps the same condition on all of their NC permits.
2D.0503 "Particulates from Fuel Burning Indirect Heat Exchangers"
Permit Conditions 2.I.A.1. and 2.I.B.1.
The boilers have never been tested for particulate. There has been no gas curtailment since the last FCE.
ES-8 and ES-9 each have an emission limit of 0.271b/MMBtu, and the temporary boilers have limits of 0.25
lb/MMBtu and 0.23 lb/MMBtu. Assuming worst case No. 6 fuel usage,boiler ES-8 and ES-9 uncontrolled
particulate emissions are estimated using an AP-42 factor:
88,400,000 Btu/hr(gallon/151,000 Btu)(24 lb/1000 gallons)= 14.05 lbs/hr emitted
14.05 lbs/hr(hr/88.4 MMBtu)=0.16 lb/MMBtu
The temporary boiler would operate on natural gas if they are needed. The AP-42 emission factor for
particulate from natural gas combustion is 0.007 lb/MMBtu. There are no
monitoring/recordkeeping/reporting(MRR) conditions for 02D. 0503. Darlings appears to be in
compliance with 02D.0503.
2D.0516 "Sulfur Dioxide Emissions from Combustion Sources"
Permit Conditions 2.1.A.2. and 2.I.B.2.
The regulation applies to the No. 6 fuel oil and natural gas combustion in the boilers. No animal fats have
ever been combusted at the facility. No monitoring is required for natural gas combustion. Permit Condition
2.1.A.2.d. states that the sulfur content in the fuel oil must not exceed 2.1%by weight. Permit condition
2.1.A.2.e. and g.require Darling Ingredients to maintain sulfur certifications per shipment of fuel oil, and to
submit semi-annual fuel oil sulfur certification summary reports to DAQ. No fuel oil shipments have been
received since 01/09/2015,and that shipment was compliant. Darling Ingredients has submitted complete
semi-annual reports on time. Darling Ingredients appears to be in compliance with 02D .0516.
2D.0521 "Control of Visible Emissions"
Permit Conditions 2.1.A.3. and 2.I.B.3.
Visible emissions from all of the boilers must not exceed 20 percent opacity when averaged over a six-
minute period. Six-minute averaging periods may exceed 20 percent not more than once in any hour and
not more than four times in any 24-hour period. There are no monitoring/recordkeeping/reporting
requirements for the temporary boilers.
When No. 6 fuel oil is combusted, emissions are vented to the packed scrubber,which creates a very
visibly wet plume. Therefore, alternative monitoring has been required to demonstrate compliance with
the visible emissions limit. Permit Condition 2.1.A.3.d. requires the following activities associated with
the packed tower scrubber:
• Emissions from the boilers must be controlled at all times by the packed bed scrubber when
combusting fuel oil(with exception of tune-ups).
• Perform semi-annual external inspection of the packed bed scrubber.
• Record the scrubber flow rate at least once per day and verify that the flow rate is within the
manufacturer's specifications.
• Perform weekly cleanouts of the scrubber and monthly instrumentation inspections.
• Scrubbing binder must be in use daily from March 1st through September 30ti'each year.
• Binder must be added weekly.
The boilers are operated on gas, and fuel oil is only used in curtailment. No fuel oil was fired for curtailment
since the date of last inspection. I reviewed the fuel usage records back to January of 2021. No fuel oil was
used during this timeframe. Mr. Haynes stated that they plan on submitting an application to combust#2 Fuel
Oil and remove the#6 Fuel Oil from the permit.
Note that the above records were reviewed as part of compliance evaluation against Specific Condition
2.2.A.1. for 02D. 0541. Darling Ingredients appears to be in compliance with 02D .0521.
15A NCAC 02Q.0317.Avoidance Conditions for
02D. 0524 "New Source Performance Standards"Subpart Dc
Permit Condition 2.I.B.4.
To avoid applicability of NSPS,any temporary boiler must meet the following requirements
• Meet the definition of a temporary boiler under NSPS 60.41 c.
• Ensure that the boiler rating doesn't exceed 90 MMBtu/hr.
• Only fire natural gas.
• Keep records demonstrating that the boiler(s)is not on-site for more than 180 consecutive days.
The temporary boiler was not on site at the time of the inspection. Darling Ingredients appears to be in
compliance with this 02D 0524.
02Q.0317"Avoidance Conditions"for
02D.0530 "Prevention of Significant Deterioration"
Permit Condition 2.I.A.4.
In order to avoid applicability of 15A NCAC 02D .0530(g)for major sources and major modifications,
boilers ES-8 and ES-9 are limited to the following emissions per consecutive 12-month period(January—
Through December 2021, data from 2021 inventory)
Pollutant 12 Month Rolling De minimus levels PSD limit
Average (tpy) (tpy)
t
PM 1.01 25 41
PM10 0.96 15 28
Sulfur dioxide 0.05 40 215
VOCs 29.14 40 40
Carbon monoxide 6.82 100 106
Nitrogen oxides 1 8.12 1 40 107
The packed tower scrubber is required to provide emissions control when the boilers are firing No. 6 fuel
oil.
Darling Ingredients is required to calculate monthly sulfur dioxide emissions from all fuels. The facility
is also required to calculate monthly carbon monoxide emissions using AP-42 factors for the emissions
from fuel oil and natural gas combustion, and 0.0170 pounds per million Btu for the emissions from
saleable animal fat combustion. No animal fat has ever been combusted at this facility.
The facility is required to keep a record of the monthly emissions along with a record of the amount of
each fuel combusted.
Permit condition 2.1.AA.g. requires the facility to submit semi-annual summary reports containing the
following information:
• the monthly sulfur dioxide emissions for the previous 17 months. The emissions must be
calculated for each of the 12-month periods over the previous 17 months.
• the monthly quantities of natural gas, saleable animal fats, and fuel oil consumed for the previous
17 months.
• the average sulfur content of the fuel oil.
• the monthly carbon monoxide emissions from the previous 17 months. The emissions must be
calculated for each of the 12-month periods over the previous 17 months.
Darling Ingredients' gas totalizer is read daily, and the daily records are all recorded on a monthly log
sheet. Fuel oil use is also tracked,but it isn't exact due to liquid expansion. Mr. Haynes uses fuel totals
provided by Corporate Accounting for the emissions inventory and reporting.
Total reported CY2021 gas usage was 162.38 MMCF. 0 gallons of No. 6 oil were combusted in the
boilers in CY2021. No fuel oil has been combusted so far this year. The rolling annual total SOz
emission has been negligible. CO rolling annual emissions are less than 10 tons so far this year. The
reports have been submitted on time. The reports are complete and demonstrate compliance with the
permit condition. Darling Ingredients appears to be in compliance with 02Q. 0317.
02D.1111 "Maximum Achievable Control Technology"
Subpart JJJJJJ-NESHAP for Boiler Area Sources
Permit Condition 2.LA.5.
This facility is a minor source of HAPs. Perdue submitted the initial notification for the boilers on 9/20/2011.
They resubmitted the initial notification on 7/12/2013 (to account for changes to the regulation). Permit
Condition 2.1.A.5. is written with the assumption that the boilers use multiple fuels. However,these boilers
have been operating on natural gas with fuel oil only used for maintenance and curtailment. As long as
boilers ES-8 and ES-9 meet the definition of a natural gas boiler as provided in the regulation,there are no
requirements under Subpart 6J. However,Darling Ingredients has completed tune-ups and energy
assessments for the boilers, so they can burn oil whenever they wish.
The facility is required to perform biennial tune-ups of the boilers. Each tune-up must include the
following:
• Inspection of the burner, and cleaning/replacement of any components of the burner as necessary.
• Inspection of the flame pattern, as applicable, and adjustment of the burner as necessary to optimize
the flame pattern. The adjustment should be consistent with the manufacturer's specifications, if
available.
• Inspection of the system controlling the air-to-fuel ratio, as applicable, and to ensure that it is
correctly calibrated and functioning properly.
• Optimization of total emissions of carbon monoxide. This optimization should be consistent with the
manufacturer's specifications, if available.
• Measurement of 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.
As part of their Corporate policy,the facility performs tune-ups two times per year,Boiler s#1 and#2(ES-8
and ES-9)were both tuned on 02/16/2022 and are scheduled to be tuned on 09/25/2022. The tune-ups were
conducted by Mid-South Steam Boiler Engineering Co, Inc.
Boiler maintenance is conducted according to weekly work orders,which I did review during the inspection.
Darling Ingredients submitted their Notice of Compliance Status on EPA's CDX-CEDRI database on
6/03/2014. A hard copy of the CDX submittal is in the WARO file. The energy assessments were completed
10/20/2014,with an update conducted on 5/27/2015. The energy assessment document is on file at the
facility. Copies of the cover page and table of contents are in the WaRO file.
Specific Condition 2.1.A.5.c.ii.C. requires documentation of the fuel used monthly by each boiler. Darling
Ingredients is recording the fuel usage under Permit Condition 2.1.A.4.f. as well. Fuel consumption records
were complete.
A biennial compliance certification is required starting 3/1/2015. The compliance certification must
contain the information specified in paragraphs 40 CFR 63.11225(b)(1)through(4) and must be
submitted upon request. The report must only be submitted to DAQ by March 15 if the facility has any
deviation described by paragraph(b)(3) of 40 CFR 63.11225. Otherwise,the report is to be kept on file at
the plant. Matt Haynes(Corporate Environmental)completes this report annually. The certifications are
on file at the facility. The most recent one is dated 01/27/2022.
Darling Ingredients appears to be in compliance with 2D.1111 and NESHAP Subpart 6J.
Six poultry meal storage silos (ID Nos. ES-11 through ES-16), one poultry meal loadout
area (ID No. ES-19), and poultry meal conveyance (IES17)
Regulated Limits/Standards Applicable Regulation
Pollutant
Particulate Matter For process rates greater than 30 tons per hour: 15A NCAC 2D .0515
E=55.OxP°-1-40
Where: E=allowable emission rate in lbs/hr
P=process weight in tons/hr
Visible Emissions 20 percent opacity 15A NCAC 2D .0521
02D.0515 "Particulates from Miscellaneous Industrial Processes"
NO PERMIT CONDITION
These sources have been deemed insignificant and are listed in the Insignificant Activities Attachment to the
permit. However,this rule still applies. See previous inspection reports for emissions estimations from the
silos and loadout. Emissions from meal conveyance are expected to be negligible. The meal is very moist,
and the system is covered. The insignificant sources appear to be in with compliance with 02D .0515.
02D.0521 "Control of Visible Emissions"
NO PERMIT CONDITION
Visible emissions from the silos,meal loadout, and meal conveyance must not exceed 20 percent opacity
when averaged over a six-minute period. Six-minute averaging periods may exceed 20 percent not more
than once in any hour and not more than four times in any 24-hour period. The insignificant sources
appear to be in compliance with 02D .0521.
2.2 -Multiple Emission Source(s) Specific Limitations and Conditions
Facility Wide Affected Sources
02D.0535 "Excess Emissions Reporting and Malfunctions"
Permit General Condition 3.La. and 3.LB.
Darling Ingredients is required to report excess emissions from deviations or malfunctions that last more
than four hours. No malfunctions have been reported since the date of last inspection. NC DAQ
Excess Emissions Forms with associated malfunction determinations are saved to SharePoint and IBEAM
Documents. Darling Ingredients is considered in compliance with 02D .0535.
02D.0539 "Odor Control of Feed Ingredient Manufacturing Plants"
Permit Condition 2.2.A.I.
There are residences on the other side of the tree line to the north that would be immediately affected by both
Darling Ingredients and Perdue odors. West Bertie Elementary School is located nearby on North Highway
308.
I performed odor surveillance along the access road and the road from Lewiston Woodville to the plant,no
odors were detected outside of the facility.
WaRO has not received a complaint call since the last inspection date. Mr. Haynes and Mr. McKinney
confirmed that Darlings Ingredients has not received any odor complaints since then as well. Mr. McKinney
is required by the company to call DAQ if they get an odor complaint. He must also immediately personally
investigate the complaint by going to the location of the complaint to evaluate, even if the odor is reported to
have occurred on a previous day. He must review previous complaint records and inspect current operation
of the plant to help determine if there is anything that needs correction. The company has an odor evaluation
form that must be completed and passed up through corporate environmental offices.
When the state odor rule for rendering plants was promulgated,the facility wished to avoid having to comply
with the storage requirements for raw materials. To do so,they must make sure that all meat is processed in
less than 36 hours, all feathers are processed within 48 hours and all used cooking oil is unloaded within 96
hours(per the rule change on 9/30/2015, Session Law 2015-264, Senate Bill 513,page 12). Otherwise,they
must store the material in properly enclosed and vented areas that have odor control. Darlings Ingredients has
an electronic card system that tracks how long raw material loads are stored before being dumped to
processing. The weigh scale tags truck delivery and departure. The scale is calibrated semi-annually. They
have a limited number of trailers, so they must dump loads quickly so the trailers can adequately serve the
customer. The computer program will change the color for a load record as it ages to alert operators that it
needs to be processed. It turns yellow at 18 hours and red at 24 hours. However,the front office usually goes
in search of loads once they've crossed 9-16 hours in storage.
Timecard data is reviewed weekly and separate hard copy reports are kept of loads that exceeded or appeared
to exceed 18 hours. It should be noted that if the electronic card records have a"7"denoted in the dump pit
column,it means that the load was shipped off-site rather than processed.
Necks and feet get processed slower because the bone must be mixed a little at a time with the other meat.
No raw material is usually allowed to just sit on the pad indefinitely. Poorly cooked material(called
"greasy meal")that is blended back into the raw material on the front end may sit on the pad but is
usually reprocessed within 3 hours. Fully cooked rejected meal can also be reprocessed, and it will sit on
the pad for up to two days. There was some rejected(fully processed)meal sitting on the pad during the
inspection. I did not smell any odor from the meal. Wet feathers are no longer pushed onto the pad for a
short while to drain. They are drained out the bottom of the truck.
MDM(mechanically deboned material) is composed of bone hash that robs protein from the meal and
creates ash in the cookers. Darlings Ingredients has installed a bin for MDM to avoid putting it on the
pad. Most MDM is shipped off-site.
I reviewed the `over 18 hours' report for January 2021 through August of 2022. All ok?
02D .0539 requires that their raw material trucks be tarped while in transport. Trailers containing raw
material sit near the receiving pad behind the office building. Empty trailers are stored in the open yard in
front of the plant. The rule does allow for uncovered raw material as long as it was generated on-site at
the Perdue processing plant. Once a trailer dumps into the receiving bay, it is washed with hot water.
This is a potential source of odor. Because the plant was preparing to start up,I only observed empty
trailers onsite during the inspection.
As long as building pressure is negative,the loading bay doors to the rendering plant do not have to be
closed all of the time. It is corporate policy to keep the large scroll doors open knee to belt level.
The rule requires Darlings Ingredients to send process gases through condensers to remove all steam and
other condensable materials. The rule requires control of expeller(press)gases. All noncondensible gases
are to be incinerated at 1,200 degrees Fahrenheit for a period of not less than 0.3 seconds or treated in an
equally effective manner. DAQ has approved control of process gases with operation of a condenser,
venturi scrubber and packed scrubber. The presses are hooded and ducted to scrubber control. Room air
goes to the crossflow scrubber.
Permit conditions 2.2.A.l.c.ii. and iii. require Darlings Ingredients to use a scrubbing binder in the cross
flow and packed bed scrubbers(CD-1OD and CD-IOF)daily from March 1 through September 30 of each
year,and to add the binder weekly with each water flush. B-10 binder is a black liquid that smells like
pine sol. It is supposed to be a self-sustaining,regenerating biological. It enhances the ability of the
water to trap noncondensibles at higher temperatures. Only about 8 oz. is required per charge. Permit
condition 2.2.A.l.e.ii. requires the facility to keep a record of when the binder is added. I reviewed the
records back to January of 2022, and they were complete. Darlings Ingredients is adding binder every
week, all year. Binder addition is noted in both the scrubbers' daily flow records and their weekly nozzle
inspection reports.
The Darlings Ingredients Quality Assurance Plan is in the WaRO file. It has not been updated since 2016.
The plan mirrors permit requirements and references use of the O&M manuals for plant equipment to satisfy a
quality assurance program. In addition to the plan Darlings Ingredients conducts annual corporate
environmental audits.
Conditions 2.2.A.Lb. and c. contain monitoring requirements for the scrubbers:
• semi-annual inspection of crossflow scrubber spray nozzles and perform maintenance and repair
when necessary to assure proper operation of the scrubber,
• monthly inspection, cleaning, and calibration of all associated instrumentation,
• semi-annual external inspection of the venturi scrubber,crossflow scrubber and packed scrubber
for structural integrity,
• weekly cleanout of the packed bed scrubber; and
• install, operate, and maintain a liquid flowmeter on the crossflow scrubber. The liquid flow rate
into each stage of the scrubber shall be no less than 500 gallons per minute of water, or water and
additives. The flows must be recorded daily.
I reviewed records for all the above monitoring back to January 2020. The records were complete, and
monitoring has been satisfactorily conducted. They perform weekly external inspection and weekly
cleanouts on all three scrubbers, as well as weekly fan maintenance checks on all three scrubbers. The
crossflow scrubber spray nozzles are inspected weekly.All of the scrubber fans,pumps and ducts have
weekly mechanical maintenance and cleanouts. The packed scrubber is drained and washed weekly. The
packed scrubber is opened every couple of months to add a detergent cleaner.
Flowmeters are inspected weekly. The flowmeters are sent out for re-calibration or replaced annually.
At least one new flowmeter is kept available on-site. The flowmeters are checked daily for mechanical
issues by operators as part of their daily maintenance route. The flow meters on both scrubbers were
replaced in o 08/29/2022.
The daily crossflow scrubber flow measurements were complete and compliant. Air flow through the
crossflow scrubber is approximately 60,000 cfm. Flow on the packed bed scrubber is also recorded every
day. It's my understanding they try to maintain a minimum 400 gpm on the packed scrubber.
The facility must submit a semi-annual summary report for all monitoring requirements. The reports have
been on time and complete.Darlings Ingredients appeared to be in compliance with 02D.0539.
02D.0540 "Particulates from Fugitive Non process Dust Emission Sources"
Permit General Condition 3.MM.
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 dust fugitives from Darlings Ingredients come from truck traffic. I did not
see any fugitive dust leave the property boundary during the inspection.
02Q.0207"Annual Emission Inventory Requirements"(Condition 2.3.x)
The facility must submit an annual emissions inventory by June 30'each year. The accuracy of the report
must be certified by a responsible official of the facility. The CY2021 inventory was submitted
electronically on 05/12/2022.
02Q.0508(n) "Compliance Certification"(Condition 2.3.P.)
The facility is required to submit an annual compliance certification to the DAQ and EPA Region 4 on or
before the first of March. The certification covers all federally enforceable terms and conditions in the
permit,including emissions limitations, standards,or work practices for the previous calendar year. It must
be signed by a responsible official. DAQ received the 2021 ACC on 01/27/2022. I have reviewed and
approved the report.
Monitoring, Recordkeeping and Reporting (MRR)
All permit-required records were reviewed back to January 2021. The facility's reports have been submitted
on time. All the reports are complete and compliant. The monitoring,recordkeeping and reporting
requirements in the permit are summarized below.
Monitoring/Recordkeeping Requirement MRR Frequency Regulation Report Required?
Fuel oil certifications must be<2.1%sulfur Each shipment 2D.0516 Certifications
Packed scrubber operation while firing oil,scrubber As applied 2Q.0317 SA Deviation report
daily flow recorded
Nat gas/fuel oil/fat used in ES-8 and ES-9 Monthly 2Q.0317 for Monthly fuel amts
(PSD Avoidance)—No fat has ever been burned 2D.0530 and and 12-month rolling
2D.1111 totals SO2 and CO
Subpart 6J bi-annual boiler tune-ups and compliance Biennial 2D.1111 No
certification(only if they burn outside curtailment or
maintenance
Temporary Boiler days of operation<180 days Record at end of operation period 2D.0524 No
Rendering truck punch cards for load processing Per load(time of receipt and time of 2D.0539 SA Deviation report
unloadin
Crossflow scrubber I&M Semi-annual nozzle inspection 2D.0539 SA Deviation report
Venturi scrubber CD-IOE and packed scrubber CD-IOF Semi-annual external inspection 2D.0539 SA Deviation report
All scrubbers Monthly instrumentation inspection 2D.0539 SA Deviation Re ort
Add scrubbing binder weekly March I'-Se tember 30' Record dates of binder addition 2D.0539 SA Deviation report
Crossflow scrubber flow rates must be>500 m Daily 2D.0539 SA Deviation report
Maintenance logbook for all scrubbers Complete as work is conducted 2D.0539 SA Deviation report
Enforcement History
Darlings Ingredients has no enforcement history in the past 5 years.
Comments/Conclusions
The facility appeared to be operating in compliance with all applicable Federal and State rules,
regulations and permit conditions and applicable regulations at the time of the inspection.