AQ_F_0400034_20220223_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY Valley Proteins,Inc. -Wadesboro Division
NC Facility ID 0400034
Inspection Report County/FIPS: Anson/007
Date: 03/14/2022
Facility Data Permit Data
Valley Proteins,Inc. -Wadesboro Division Permit 06467/T21
656 Little Duncan Road Issued 11/22/2021
Wadesboro,NC 28170 Expires 12/31/2024
Lat: 35d 2.1192m Long: 80d 4.9683m Class/Status Title V
SIC: 2077/Animal And Marine Fats And Oil Permit Status Active
NAICS: 311613/Rendering and Meat Byproduct Processing Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP/Title V
Mike Craumer Mike Craumer Matt Haynes MACT Part 63: Subpart 6J
NSPS: Subpart Dc
General Manager General Manager District Environmental
[phone] X28101 [phone] X28101 Manager
[phone]
Compliance Data
Comments:
Inspection Date 02/23/2022
Inspector's Name Jeffrey D.Cole
Inspector's Signature: Operating Status Operating
Compliance Status Compliance-inspection
Action Code FCE
Date of Signature: /z/ Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2020 0.1400 0.1800 29.08 18.88 24.43 0.1400 1046.80
2019 0.1400 0.1700 27.61 19.24 23.20 0.1400 994.12
2018 0.1300 0.1400 25.40 17.16 21.34 0.1300 914.45
* Highest HAP Emitted(in pounds)
Five Year Violation History:
Date Letter Type Rule Violated Violation Resolution Date
10/30/2020 NOWNRE NCGS 143-215.108A Control of sources of air pollution; 11/16/2020
construction of new facilities;alteration or expansion of exis
10/07/2020 NOV NCGS 143-215.108A Control of sources of air pollution; 11/16/2020
construction of new facilities;alteration or expansion of exis
06/04/2020 NOV NCGS 143-215.108A Control of sources of air pollution; 06/22/2020
construction of new facilities;alteration or expansion of exis
Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested

I. DIRECTIONS TO SITE: From FRO, follow traffic circle to second left on Gillespie Street for
0.3 miles. Turn right on Russell Street for 0.5 miles. Turn left on Robeson Street for 2.4 miles. Turn
left on Raeford Road, Hwy 401 South for 20.4 miles through Wagram. South of Wagram,NC,take
Old Wire Road(NC 144)for 12.3 miles to US74. Follow US 74 West for 39.7 miles through
Wadesboro, and turn right(north)onto US52. Go—2 miles, pass Triangle Brick on right, go 1l4 mile,
and the entrance to the Valley Protein plant is on the right(656 Little Duncan Rd.)
II. SAFETY: Hard hat, safety glasses, safety boots,hearing protection; gloves and a wipe rag are
advisable. The greatest hazard to the inspector is either slipping on stairs or burn from a leaking
steam pipe. Steam is used extensively, and there are always puddles that reduce boot traction. An
inspector is consciously or subconsciously tentative about touching railing at a rendering plant,which
could increase the chance of falls. Keep fingers out of your mouth during the inspection, and wash
hands thoroughly when finished.
III.FACILITY DESCRIPTION: The facility renders chicken feathers and fat for a number of
processors. Currently,blood and offal are sent to other plants.They use several rendering methods to
make four products: feather meal,pet-food-grade protein meal, feed-grade meal (poultry food
additive),and two grades of fat. The majority of the fat is sold as a feed additive but can also be used
as boiler fuel when fuel prices warrant. There are five uncontrolled boilers that supply steam to the
processes; additionally,boilers B-1,B-2 and B-3 serve as odor control devices. Boiler B-5 is a
temporary boiler that hasn't been on site in years. The primary control for the intensive rendering
emissions is the evaporation of condensables,then oxidation within the boilers. An alternate scenario
is directing non-condensable emissions through the wet scrubber and cross-flow scrubber,normally
used only for control of the lower intensity odors from room air. This facility employs—145 workers,
including drivers,and operates 24 hours for 5-and one-half days each week;the remaining one- and
one-half days are consumed by maintenance and inspections. The facility opens each control device
every Sunday for cleaning and inspections.
IV. INSPECTION SUMMARY: On 23 February 2022, I, Jeffrey Cole of DAQ FRO,arrived at Valley
Protein to conduct an air quality compliance inspection. Before pulling into the facilities parking lot,
I drove along Little Duncan Road for 0.5 miles, from the turn off NC Hwy 52 to approximately one
quarter mile past the plant.Except for the part of Little Duncan Road that is in front of the plant, I did
not detect any rendering or other odors. After arriving back at the plant,I met with James Hodges,
Environmental Manager. Mr.Hodges reviewed the FacFinder data and noted that one phone number
needed to be updated. This change was made in IBEAM after I returned to the FRO. There are 4,248
gallons of No. 6 fuel oil and 11,258 gallons of saleable animal fat on-site. The previous inspection
noted 19,773 gallons of No. 6 fuel oil and 21,650 gallons of saleable animal fat stored on-site. Mr.
Hodges explained that the company chose to combust both these fuels(at separate times in Boiler B-4
only) since the last inspection because these fuels had been in the tanks for a long time and the
company made a decision to reduce the volume of these older fuels.
All of the facility's records of I&M appeared complete,and there were no noted concerns. We next
reviewed the facility's latest boiler tune-up records. The facility tunes the boilers semiannually, and
the records sent to Mr.Hodges showed the last tune-ups were completed on 20 September 2021.
After reviewing the facility's records,Mr.Hodges and I toured the facility. Upon entering the control
office,we noted that the facility's process computer showed the longest duration that any material
had been waiting on site was—27 hours. Mr.Hodges was unaware of this long duration as normally
any load that has been onsite for more than 14 hours requires that management be informed. He was
concerned as the permitted limit of hours for the material waiting was 36 hours. Mr. Hodges
explained that new personnel were recently hired and training about this permit requirement had not

been done. Mr. Hodges contacted me after the inspection and confirmed that the material was
processed later that afternoon at 29 hours onsite.
All scrubbers were operational,and their gauge readings(flow rate/pressure,ORP)were within the
permit limits. The facility was not rendering material during the inspection as the water supply to the
boilers was cut off and was under repair.
PERMITTED EMISSION SOURCES:
Emission, Control
Source ; Emission Source Description I Device Control Device Description
Ili No.
5
a
i ID'No.
Two natural gas/No.2 fuel oil/No.6
B-1 and 1 fuel oil/On Specification recycled No.
B-2 4 equivalent fuel oil/saleable fat-fired
GACT 1 boilers(33.0 million Btu per hour heat N/A NIA
JJJJJJ ; input rate each)
Not Operating—no water available
B-3 One natural gas/No.2 fuel oil/saleable
NSPS DC It fat-fired boiler(48.4 million Btu per N/A N/A
GACT hour heat input)
JJJJJJ 1 Alot Operating—no water available
One natural gas/No.2 fuel oil/No. 6
B-4 fuel oil/On Specification recycled No.
4 equivalent fuel oil/saleable fat-fired
GACT N/A N/A
boiler(33.5 million Btu per hour heat
JJJJJJ input)
f
Not Operating—no water available
One natural gas/No.2 fuel oil/No. 6
t fuel oil/On Specification recycled No.
B-5 4 equivalent fuel oil/saleable fat-fired
GACT boiler(29.3 million Btu per hour heat N/A N/A
JJJJJJ input)
No longer on site;inoted to another
fcaeilitl

f
E6 Feather and Blood Rendering
process consisting of:
One air cooled condenser
C-5 in series with
E9 One rotary steam tube dryer
One venturi scrubber(minimum scrubber
C-1 liquid inlet pressure 9 psig)with a
.Not operating
Mist eliminator
} j GI operating at II psig
One feather hydrolyser
Not operating One cyclone(60-inch diameter)with a
k Mist eliminator in series with a
C-2 venting f
z combination of three natural gas/fuel oil
to either /saleable fat-fired boilers
t CY-1 One packed tower scrubber(minimum
CM-1
s scrubber liquid inlet pressure 3 psig)
B-1 to B-3 or
Two natural gas#itel oil/saleable fat
f C-4
fired boilers(B-1 and B-2)operating as
control dei,iees;C-4 operating at 15 psig
One venturi scrubber(minimum scrubber f
E 10 One feather press liquid inlet pressure 5 psig)in series with
C-3 One packed tower scrubber(minimum
{
scrubber liquid inlet pressure 3 psig)
:Tot operating
C-3 operating at 14 psig;C-4 operating
at 15 psig
C-4
E i
E 1 € Rendering process consisting of C-6 One air cooled condenser
One three stage slurry system in series with
evaporative condenser cooker with 3 C-1 One venturi scrubber(minimum scrubber
{ post heater forced circulation liquid inlet pressure 9 psig)with a
chamber on 1 st stage e Mist eliminator
C=1 operating at II psig
Not Operating
} k C-2 venting F One cyclone(60 inch diameter)with a
to either Mist eliminator in series with a
CY-1 combination of three(3)natural gas/fuel
CM-1 oil/saleable fat-fired boilers
B-1 to B-3 or I One packed tower scrubber(minimum
C-4 scrubber liquid inlet pressure 3 psig)
Tivo natural gas/fuel oil Aaleable_fat-
fired boilers(B-1 and B-2)operating as
control dexlices;C 4 operating at 15 psig
3 ' i
One venturi scrubber(minimum scrubber t
E 18 One fluidizer tank C-3 1 liquid inlet pressure 5 psig)in series with
One packed tower scrubber(minimum
Not operating scrubber liquid inlet pressure 3 psig)
� p g q p p g)
f C-4 I e 3 operating at 14 psig;C-4 operating
at 15 psig

One air cooled condenser
E7 One 320U cooker C-7 in series with
F
One venturi scrubber(minimum scrubber
Operating C-1 liquid inlet pressure 9 psig)in series with
� a Mist eliminator
C-1 operating at 11 psig
One cyclone(60-inch diameter)with a
C-2 venting Mist eliminator in series with a
to either combination of three natural gas/fuel
CY-1 oil/saleable fat-fired boilers
} CM-1 One packed tower scrubber(minimum
B-1 to B-3 or scrubber liquid inlet pressure 3 psig)
C-4 Two natural gas/fuel oil/saleable fat-
fired boilers(B-I and B-2) operating as
control devices;C-4 operating at 15 psig
� p g p� g
f
i
t
I One venturi scrubber(minimum scrubber
Press/centrifuge process liquid inlet pressure 5 psig)in series with
E8 i C-3 One packed tower scrubber(minimum
Vot operating scrubber liquid inlet pressure 3 psig)
C-4 C-3 operating(it 14 psig;f-4 operating
at 15 psig
One,two stage,cross-flow type-wet
scrubber,minimum scrubber liquid inlet
1 Plant room air system pressure 13 psig with mist eliminator,
E22 Operating C-8 i utilizing chlorine dioxide or a sulfate-
based odor oxidizing solution.
Scrubber C-8 was shown operating at 22
psig(Stage 1)and 25 psig(Stage 2)

V. APPLICABLE AIR QUALITY REGULATIONS:
2.1 -Emission Source(s) and Control Devices(s) Specific Limitations and Conditions
A. Two natural gas/No. 2 fuel oil/No. 6 fuel oil/On Specification recycled No. 4 equivalent fuel
oil/saleable fat-fired boilers(ID Nos.B-1 and B-2),
One natural gas/No.2 fuel oil/saleable fat-fired boiler(ID No.B-3),
One natural gas/No. 2 fuel oil/No. 6 fuel oil/On Specification recycled No. 4 equivalent fuel
oil/saleable fat-fired boiler(ID No.B-4),and
One natural gas/No. 2 fuel oil/No. 6 fuel oil/On Specification recycled No. 4 equivalent fuel
oil/saleable fat-fired boiler(ID No.B-5)
1. 15A NCAC 2D .0503 PARTICULATES FROM FUEL BURNING INDIRECT HEAT
EXCHANGERS—Emissions of particulate matter from boilers into the atmosphere shall not
exceed 0.367 lb/mmBtu for boilers 13-1 and B-2, 0.318 lb/mmBtu for boiler B-3, 0.30 lb/mmBtu
for boiler B4, and 0.28 lb/mmBtu for boiler B-5.
APPEARED IN COMPLIANCE—The facility was not rendering material during the inspection
as the water supply to the boilers was cut off due to a pressure valve malfunction that was
preventing water flow. This malfunction was under repair at the time of the inspection. The
facility normally fires natural gas but chose to combust 15,489 gallons of No. 6 fuel and 10,392
gallons of saleable animal fat in 2021 to reduce the amount of these fuels in their onsite tanks.
The AP-42 emission factor for natural gas is 0.007 lb/mmBtu. Source testing at the facility in
April 2001 resulted in a PM emission factor of 0.05 lb/mmBtu while combusting saleable animal
fat. The AP-42 PM emission factor for No. 4 fuel oil is 0.05 lb/mmBtu. The AP-42 PM emission
factor for No. 6 fuel oil is 0.06 lb/mmBtu.
2. 15A NCAC 2D .0516 SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
—Sulfur dioxide emissions from the facility's boilers shall not exceed 2.3 lb/mmBtu. The
Permittee shall monitor the sulfur content of the No. 6 fuel oil and recycled No. 4 fuel oil by
using fuel oil supplier certifications per shipment received;the sulfur content of the No. 6 is
limited to 2.1 %and the recycled No. 4 to 2.0%. Recordkeeping and semiannual reporting.
APPEARED IN COMPLIANCE—The S02 AP-42 emission factor for natural gas is
0.0006 lb/mmBtu and for 0.5%S No. 2 fuel oil is 0.02 lb/mmBtu. The worst-case fuel is No. 6 at
2.1%sulfur (current fuel certification), would emit S02 at rate of 1.7 lbs/mmBtu. The last test on
the facility's No. 6 fuel oil was 0.54%sulfur. This testing was done at the last purchase of No.6
fuel oil was 313114. The last testing of the saleable fat onsite, conducted on 12113121, recorded a
sulfur content of 0.009%.
3. 15A NCAC 2D .0521 CONTROL OF VISIBLE EMISSIONS—The visible emissions from the
facility's emission sources shall not be more than 20%opacity. The Permittee shall observe the
visible emissions from the boilers while firing on No. 6 fuel oil,recycled No. 4 fuel oil,No. 2 fuel
oil and animal fat oil,and from the rendering processes daily against"normal." Recordkeeping
and semiannual summary reporting.
APPEARED IN COMPLIANCE—The facility was not rendering material during the inspection
as the water supply to the boilers was cut off and was under repair. There were no visible
emissions noted from the scrubber exhausts. In 2021, the company chose to combust 15,489

gallons of No. 6 fuel and 10,392 gallons of saleable animal fat in Boiler B-4 dining separate
periods. The facility goes beyond the permit's requirements by performing observations of all
boiler stacks on all operational days firing any fuel type since the last inspection. The facility's
VE log is well organized and there were no abnormal or excess emissions noted. The company
has a Method 9 certified employee on site. The semiannual report was received on 1120122 and
indicated compliance.
4. 15A NCAC 2D .0524 NSPS 40 CFR PART 60 SUBPART De—The maximum sulfur content
of any fuel oil combusted in Boiler B-3 shall not exceed 0.5%,and the maximum VE shall be
20%. The Permittee shall record and maintain records of the amounts of No. 2 fuel oil combusted
during each month and of the sulfur content through fuel supplier certifications. Semiannual
reporting.
APPEARED IN COMPLIANCE—The facility was not rendering material during the inspection as
the water supply to the boilers was cut off and was under repair. Boiler B-3 has only fired natural
gas since the last inspection. The semiannual report was received on 1120122 and indicated
compliance.
5. 15A NCAC 2Q .0317 AVOIDANCE OF PREVENTION OF SIGNIFICANT
DETERIORATION for SOz and CO—Boilers B-1,B-2,B-3 and B-4 shall discharge less than
250 tons of sulfur dioxide and carbon monoxide per consecutive twelve-month period. The
Permittee shall record the amounts of natural gas,No.2 fuel oil,No. 6 fuel oil, On Specification
No. 4 recycled fuel oil, and saleable animal fat combusted in the boilers each month;the
Permittee shall also calculate the amounts of carbon monoxide and sulfur dioxide emitted each
month.
APPEARED IN COMPLIANCE—The monthly records appear to be complete, and emissions
appear to be calculated correctly using the fuel emission factors listed in the facility's annual
emissions inventory. The records show the that 572,275 mmcf of NG, 0 gallons of No. 2 fuel oil,
17,796 gallons of No. 6 fuel oil, 0 gallons of off specification, recycled, No. 4 fuel oil and 10,392
gallons of saleable animal fat were combusted in 2021. The following tables show boiler annual
(CU2021) emissions and the most recent 12 month emissions based on fuel combusted.
�nnutt XY VEtn ssi©t
Natural Gas 24.0 0.17 i
No. 6 fuel oil _ � � 0.04 �— —� 2.93 — �
Saleable Animal Fat 0.001 �U ; �. M_= ..�...,. .H.._.. 0.012�
Total Emissions 24.0 3.11
fine most recent{, 'ebruary
20 t tr©t .1��r�zuary Zlt 2} CO 0 so {tvn)
rQm trio boiler
,fuel
Natural Gas 23.1 0.16
No. 6 fuel oil 0.04 2.93
Saleable Animal Fat � 0.001 � 0.012
Total Emissions 23.1 3.01

The emissions records show that the facility below both the 250 tons of sulfur dioxide and carbon
monoxide limits per consecutive twelve-month period.
6. 15A NCAC 2D .0501 COMPLIANCE WITH NATIONAL AMBIENT AIR QUALITY
STANDARDS—The daily emission of sulfur dioxide from Boilers B-1,B-2,B-3,B-4 and B-5
shall not exceed 3,644.49 pounds per day. The permit allows calculations based on the PSD
avoidance(monthly)calculations, divided by 30.
APPEARED IN COMPLIANCE—The facility makes daily calculations of SOz emissions based
on fuel combusted the previous day. Mr. Hodges noted that the sulfur dioxide emitted from
Boilers B-1, B-2, B-3, B-4 and B-5 on 2121122 (based on the PSD avoidance[monthly]
calculations, divided by 30)was 426.3 pounds. This is much higher than the 1.1 pounds recorded
on 2124121 documented during the previous inspection. Mr. Hodges stated that the combustion of
the No. 6 fuel oil in 2021 accounted for this large difference in emissions. This higher level is
still far below the permitted limit.
7. 15A NCAC 2D .1111: MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY—For
Boilers B-1,B-2,B-3,B-4 and B-5,the Permittee shall comply with all applicable provisions,
including the notification,testing, and monitoring requirements contained in Environmental
Management Commission Standard 15A NCAC 02D .1111, "Maximum Achievable Control
Technology" as promulgated in 40 CFR 63, Subpart JJJJJJ, "National Emission Standards for
Hazardous Air Pollutants for Area Sources: Industrial,Commercial, and Institutional Boilers",
including Subpart A "General Provisions." These include a one-time energy assessment, a
Notification of Compliance Status(NOCS),biennial/triennial or every five year tune-ups,what
and how often testing,records,reporting, etc).
APPEARS IN COMPLIANCE—The one-time energy assessment for this facility was conducted
on 1110713 and 11108113. The facility conducted their initial tune-up work practice or
management practice standard on all boilers present onsite on 03121112. The NOCS was
submitted on 06/03/14 for all boilers onsite. The most recent tune-ups were done on 12121121 for
all boilers onsite. No boilers were operating at the time of the inspection as the water supply to
the boilers was cut off and was under repair.
B. Feather and Blood Rendering process including:
a) One feather hydrolyser(ID No.E9),
b) One rotary steam tube dryer(ID No.E6)controlled by:
One air-cooled condenser(ID No. C-5)in series with one venturi scrubber(ID No.C-1)with a
mist eliminator (ID No. C-2) in series with either one cyclone (ID No. CY-1) with a mist
eliminator(ID No. CM-1)in series with a combination of three natural gas/fuel oil/saleable fat
fired boilers (ID Nos. B-1, B-2, and B-3) or packed tower scrubber (ID No. C-4). Condenser
C-5 may vent directly to cross-flow scrubber C-8 for up to 4,380 hours per year.
c) One feather press (ID No. E10) controlled by a venturi scrubber(ID No. C-3)in series with a
packed tower scrubber(ID No.C-4)
Rendering process including:
a) One three stage slurry system evaporative condenser cooker with post heater forced
circulation chamber(ID No.E1)controlled by:
One air-cooled condenser(ID No.C-6)in series with one venturi scrubber

(ID No. C-1)with a mist eliminator(ID No. C-2)in series with either one cyclone(ID No. CY-
1)with a mist eliminator(ID No. CM-1)in series with a combination of three natural gas/fuel
oil/saleable fat fired boilers (ID Nos. B-1,B-2, and B-3) or packed tower scrubber (ID No. C-
4). Condenser C-6 may vent directly to cross-flow scrubber C-8 for up to 4,380 hours per
year.
b) One fluidization tank(ID No. E18)controlled by a venturi scrubber(ID No. C-3)in series
with a packed tower scrubber(ID No. C-4)
c) One 320U cooker(ID No.E7)controlled by:
One air-cooled condenser (ID No. C-7) in series with one venturi scrubber (ID No. C-1) in
series with one mist eliminator (ID No. C-2) in series with either one cyclone (ID No. CY-1)
with a mist eliminator (ID No. CM-1) in series with a combination of three natural gas/fuel
oil/saleable fat fired boilers (ID Nos. B-1,B-2, and B-3) or packed tower scrubber (ID No. C-
4). Condenser C-7 may vent directly to cross-flow scrubber C-8 for up to 4,380 hours per
year.
d) Press/centrifuge process(ID No.E8)controlled by:
Venturi scrubber(ID No.C-3)in series with packed tower scrubber(ID No.C-4)
1. 15A NCAC 2D .0515 PARTICULATES FROM MISCELLANEOUS INDUSTRIAL
PROCESSES—Emissions of particulate matter from the feather hydrolyser(ID No. E9),rotary
steam tube dryer(ID No. E6),feather press(ID No. E 10)and rendering process(ID No. E 1),
shall be controlled by a series of control devices(venturi scrubbers, cyclones, and mist
eliminators)and shall not exceed those calculated by E=4.10 * P°67,where E is the allowable
emission rate in lb/hr;this is accomplished by properly maintaining the control devices. The
Permittee shall perform a monthly visual inspection, including all ductwork, and an annual
internal inspection of condensers and venturi/packed tower scrubbers.
APPEARED IN COMPLIANCE—Particulate matter emission source testing for the rotary
steam tube dryer (ID. No. E6), the 320 U cooker system (ID No. E7) and the feather hydrolyser
(ID No. E9) was conducted on November 18 and 19, 2009. The average process rate during
testing of the feather system (E6&E9) was 12.68 tons/hour, therefore the total PM emissions
limit was 22.5 pound per hour(lb/hr). The average process rate during testing of the 320U
cooker system was 21.76 tons per hour, therefore the total PM emissions limit is 32.3 pound per
hour(lb/hr). Test results on the last control device on each of these processes (i.e., venturi
scrubber, ID No. C-1) showed an emission rate of 0.71 lb/hour. The facility performs monthly
visual inspections, including all ductwork, and an annual inspection of condensers and
venturi/packed tower scrubbers. The last monthly inspection of the controls was on 31612022 and
the last annual inspection was on 811512021.
2. 15A NCAC 2D .0521 CONTROL OF VISIBLE EMISSIONS—The visible emissions from the
facility's emission sources shall not be more than 20% opacity. The Permittee shall observe the
visible emissions from the boilers while firing on No. 6 fuel oil,recycled No. 4 fuel oil,No. 2 fuel
oil and animal fat oil, and from the rendering processes daily against"normal." Recordkeeping
and semiannual summary reporting.
APPEARED IN COMPLIANCE—The facility was not rendering material during the inspection
as the water supply to the boilers was cut off and was under repair. There were no visible
emissions noted from the scrubber exhausts. The facility is performing observations and their VE
log is well organized and there were no abnormal or excess emissions noted. The semiannual
report was received on 1120122 and indicated compliance.

3. 15A NCAC 02Q.0317: AVOIDANCE CONDITIONS for 15A NCAC 02D.0530:
PREVENTION OF SIGNIFICANT DETERIORATION—The rendering process(ID Nos.El)
and the feather and blood rendering process(ID Nos.E6,E7,and E9),while operating under the
alternate control bypass scenario(ALBS)venting to the crossflow scrubber(ID No.C-8), shall
discharge into the atmosphere less than 250 tons of particulate matter(PM)per consecutive 12-
month period. Less than 4,3 80 hours per year when venting to C-8.Record monthly,the hourly
duration of the ACBS.
APPEARED IN COMPLIANCE—Mr. Hodges noted that the facility had not operated in the
ACBS bypass mode since the last permit was issued.
2.2-Multiple Emission Source(s)Specific Limitations and Conditions
STATE-ONLY REQUIREMENT:
A. Feather and Blood Rendering process including:
a) One feather hydrolyser(ID No.E9),
b) One rotary steam tube dryer(ID No.E6)controlled by:
One air-cooled condenser(ID No. C-5)in series with one venturi scrubber(ID No. C-1)with a
mist eliminator (ID No. C-2) in series with either one cyclone (ID No. CY-1) with a mist
eliminator(ID No.CM-1)in series with a combination of three natural gas/fuel oil/saleable fat
fired boilers (ID Nos. B-1, B-2, and B-3) or packed tower scrubber (ID No. C-4). Condenser
C-5 may vent directly to cross-flow scrubber C-8 for up to 4,380 hours per year.
c) One feather press (ID No. E10) controlled by a venturi scrubber(ID No. C-3)in series with a
packed tower scrubber(ID No.C-4)
Rendering process including:
a) One three stage slurry system evaporative condenser cooker with post heater forced
circulation chamber(ID No.El)controlled by:
One air-cooled condenser(ID No. C-6)in series with one venturi scrubber
(ID No. C-1)with a mist eliminator(ID No.C-2) in series with either one cyclone(ID No. CY-
1)with a mist eliminator(11D No. CM-1)in series with a combination of three natural gas/fuel
oil/saleable fat fired boilers (ID Nos. B-1, B-2, and B-3) or packed tower scrubber (ID No. C-
4). Condenser C-6 may vent directly to cross-flow scrubber C-8 for up to 4,380 hours per
year.
b) One fluidization tank(ID No.E18) controlled by a venturi scrubber(ID No. C-3)in series
with a packed tower scrubber(111)No. C-4)
c) One 320U cooker(ID No.E7)controlled by:
One air-cooled condenser (ID No. C-7) in series with one venturi scrubber (ID No. C-1) in
series with one mist eliminator (111) No. C-2) in series with either one cyclone (ID No. CY-1)
with a mist eliminator (ID No. CM-1) in series with a combination of three natural gas/fuel
oil/saleable fat fired boilers (ID Nos. B-1,B-2,and B-3) or packed tower scrubber(ID No. C-
4). Condenser C-7 may vent directly to cross-flow scrubber C-8 for up to 4,380 hours per
year.
d) Press/centrifuge process(ID No.E8)controlled by:
Venturi scrubber(ID No.C-3)in series with packed tower scrubber(ID No.C-4)

1. 15A NCAC 2D .0539 ODOR CONTROL FOR FEED INGREDIENT MANUFACTURING
PLANTS—The Permittee shall ensure that odorous emissions are controlled by control devices
as listed in the permit and the Permittee shall install,operate and maintain parameter measuring
and recording devices for these devices. All gases from plant room air, feather and blood
rendering,and rendering process shall pass first through the condensers and then be incinerated at
1,200 degrees for 0.3 seconds while the boilers are not in low fire(or treated in an equally
effective manner. All expeller units shall be properly hooded, and all exhaust gases directed to
odor control equipment. The Permittee shall take reasonable precautions to prevent odor
discharge during handling,transportation and storage of incoming materials. The Permittee shall
ensure that all odor control devices are inspected,maintained and operated properly; external
inspections monthly, scrubber nozzles cleaned monthly, generation units calibrated monthly, and
a semi-annual internal inspection for all control devices. The Permittee shall ensure the venturi
(C-1)inlet water pressure at a 9 psig minimum,the venturi(C-3) inlet water pressure at a 5 psig
minimum,the packed bed scrubber(C-4) inlet water pressure at a 3 psig minimum,the cross-flow
(C-8)generation unit at a+300 mV ORP minimum and the scrubber inlet water pressure at a
13 psig minimum. The Permittee shall monitor the boiler operating parameters once per day for
confirmation of boiler operation above low fire if being used for odor control. The Permittee
shall record all parameters, inspections and maintenance in a logbook.
Unloading Specific Raw Materials: A vehicle or container holding raw material.which has not
been unloaded inside or parked inside an odor-controlled area within the facility, shall be
unloaded for processing of the raw material prior to the expiration of the following time limits:
a. For feathers with only trace amounts of blood, such as those obtained from slaughtering
houses that separate blood from offal and feathers, no later than 48 hours after being
weighed upon arrival at the facility.
b. For used cooking oil in sealed tankers, no later than 96 hours after being weighed upon
arrival at the facility.
c. For all other types of raw material not in sealed containers,no later than 36 hours after
being weighed upon arrival at the facility.
APPEARED IN COMPLIANCE—Storage of material while on-site is tracked electronically.
The longest any material was onsite during the inspection was—27 hours. The company has a
handwritten log in the scale house where they record any loads that go over 18 hours. Eighteen
hours is their warning that something must happen with the load quickly. If a load reaches the
18-hour mark the General Manager and Plant Manager are notified to ensure the load is dealt
with. Mr. Hodges explained that this was the first load exceeding the 18-hour mark in the last
3 years. Mr. Hodges was not pleased with the time that this load was onsite and called the
appropriate employees to get this load processed quickly. He later explained that new personnel
were recently hired and training about this permit requirement had not been done. Mr. Hodges
contacted me after the inspection and confirmed that the material was combusted later that
afternoon at 29 hours onsite.
While the facility was not rendering material during the inspection as the water supply to the
boilers was cut off and was under repair, my inspection noted that all scrubbers were
operational, and their gauge readings (flow rate/pressure, ORP) were within the permit limits.
Venturi C-1 (9 psig minimum) was operating at 11 psig, venturi C-3 (5 psig minimum) was
operating at 13 psig. The packed tower scrubber C-4 (3 psig minimum) was operating at 15 psig.
Scrubber C-8 (each stage's psig at a 13 psig minimum) was shown operating at 22 psig(Stage 1)
and 25 psig(Stage 2). The ORP values were observed to be +817 mV(Packed Tower Scrubber
C4) and+418 mV(Stages I and II of Cross-Flow Scrubber C8). The operator's log for checking

high fire status, when the boilers are used for odor control, included readings taken and logged
during each shift and appeared complete.
The facility has a rigorous cleaning and inspection regimen, which exceeds the permit
requirement and is completed weekly. Calibrations are completed monthly by Chemtreat,
utilizing a chlorine dioxide or a sulfate-based odor oxidizing solution. All the internal duct work
including the inside of the scrubbers was cleaned on 02124122.
The DAQ has received one odor complaint since the last inspection (on 10121121). This
complaint was investigated but the odor noted could not be detected where the complainant had
stated the odor had been. Therefore, this investigation was completed with no action taken
against Malley Proteins— Wadesboro Division.
STATE ONLY REQUIREMENT:
B. Boilers(ID Nos.B-1,B-2,B-4,and B-5)
1. 15A NCAC 2Q.0317 AVOIDANCE CONDITION FOR 15 A NCAC 2D .1100: CONTROL
OF TOXIC AIR POLLUTANTS—The Permittee shall only combust recycled No. 4 fuel oil that
meets the specifications listed in the permit. The Permittee shall record the amount of recycled
No. 4 delivered to and combusted at the facility and retain the results of analytical testing.
APPEARED IN COMPLIANCE—Mr. Hodges stated that no recycled No. 4 fuel oil has been
purchased or combusted since 2005. There is no recycled No. 4 fuel oil on-site.
SECTION 3 - GENERAL CONDITIONS
GENERAL CONDITION"I"—REPORTING REQUIREMENTS FOR EXCESS
EMISSIONS AND PERMIT DEVIATIONS—The Permittee shall report excess emissions in
accordance with 15A NCAC 21) .0535 and report any permit deviations quarterly.
APPEARED IN COMPLIANCE—Mr. Hodges is aware that the permit requires reports of
excess emissions and of deviations and submits reports if required. He noted no incidents since
the last inspection.
GENERAL CONDITION"P"—COMPLIANCE CERTIFICATION—The Permittee shall
submit a compliance certification annually no later than March 1"
APPEARED IN COMPLIANCE—The facility's 2021 ACC was received on 02120122 and
appeared to show compliance.
GENERAL CONDITION"X"—ANNUAL EMISSION INVENTORY REQUIREMENTS—
The Permittee shall submit an annual emission inventory for the previous year no later than June
30th.
APPEARED IN COMPLIANCE—The facility's CY2020 AQEI was received on 06108121 and
appeared complete and accurate.
GENERAL CONDITION"DD"-PREVENTION OF ACCIDENTAL RELEASES-
SECTION 112(r)"—If the Permittee is required to develop and register a Risk Management Plan

with EPA pursuant to Section 112(r)of the Clean Air Act,then the Permittee is required to
register this plan in accordance with 40 CFR Part 68.
APPEARS IN COMPLIANCE—The facility does not store any subject chemical compounds in
quantities that would require a written Risk Management Program (RAMP).
GENERAL CONDITION"MM"—FUGITIVE DUST CONTROL REQUIREMENT
REQUIREMENTS—Particulates from Fugitive Dust Emission Sources,"the Permittee shall not
cause or allow fugitive dust emissions to cause or contribute to substantive complaints or excess
visible emissions beyond the property boundary.
APPEARS IN COMPLIANCE—Mr. Hodges stated that the facility had any dust complaints
since our last inspection. FRO has also not received and dust complaints about this facility.
VI. INSIGNIFICANT ACTIVITIES:
Emission Source I.D. Emission Source Description
IE-21.15 IE-21.2, and One load-out operation consisting of two truck loadout bays in a building
' IE-21.3 open on two ends with tractor trailer truck overhead doors, and one railcar
loadout open to the atmosphere.
IE24.1,IE-24.2, and
One grinding operation consisting of three(3)hammermill/shaker screen
IE-24.3 ? systems in a building open on two ends with tractor trailer truck overhead
x
doors
IE-26 HIVAC system
VII. NON-COMPLIANCE HISTORY SINCE 2010:
10/30/2020 NOCV/NRE issued due to facility not submitting response and permit application by
10/21/20 as the required permit application not submitted by 10/7/20 NOCV. Required
permit application was received on 11/16/20. Facility response indicated staff turnover
contributed to the violation and non-response;therefore, enforcement was not pursued.
10/07/2020 NOCV for a required permit application that was not received as of 10/07/2020.
06/04/2020 NOV for operating a control device in a way that was not permitted.
VIII. CONCLUSIONS AND RECOMMENDATIONS:
Valley Proteins,Inc.—Wadesboro Division appeared to be operating IN COMPLIANCE with their air
quality permit on 02/23/22.
PINK SHEET ADDITIONS:
None
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