AQ_F_0800109_20210113_CMPL_InspRpt (4)

NORTH CAROLINA DIVISION OF Washington Regional Office
AIR QUALITY Perdue Foods LLC-Lewiston
NC Facility ID 0800109
Inspection Report County/FIPS:Bertie/015
Date: 01/14/2021
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
NAILS: 311615/Poultry Processing Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP/112r
Tim Mizelle Frank Koekkoek Ashton Weller MACT Part 63: Subpart 6J
Environmental Manager Director of Operations Environmental
[phone] [phone] Technician
[phone]
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 01/13/2021
inspection. Inspector's Name Kurt Tidd
Operating Status Operating
Compliance Code Compliance-inspection
Action Code FCE
nn� On-Site Inspection Result Compliance
Inspector's Signature:
Date of Signature: 01/19/2021
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 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,
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).
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• 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 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.
Safetv 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
95,386,132 chickens went through the processing facility in 2020. The facility operates 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.
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• 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 on 01/13/2021. The
inspection was completed with assistance from 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 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) N/A Both of these have been removed from
(NESHAP) The engines were not operating.They are for 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. Natural gas usage for CY2020 was 152,400 scf.
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 109.E psi 113.6 psi
Visible emissions 0% 0%
Fuel Natural Gas Natural Gas
Steam 12,193 lbs/hr 4,879 lbs/hr
Stack temp 3540F 3530F
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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No visible emissions were observed from the baghouses. The area around the bagfilters was clean.
Pressure gauges are on the baghouses.
The following list of insignificant sources is attached to the permit:
I F 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 F2Q .0102(h)(5) Weller confirmed there have
(4.4 million Btu per hour maximum heat input) been no physical or operational
Wastewater treatment system 2Q .0102(g)(6) changes to either the singers or
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 112R(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/Regulatory 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.
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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. 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 or malfunctions have been reported since the last
FCE. Perdue appears to be in compliance with 2D.0535.
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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 a contractor performs quarterly internal inspections,which
count as an annual inspection. I reviewed the weekly external inspections for CY2020. There were no
missing records. I reviewed the quarterly internal inspection records dated 11/142020, 8/29/2020, 6/6/2020
and 2/29/2020. The records appeared to be complete.
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. Perdue reported a curtailment on Boiler#2 on 1/18/2020 from 11:07
PM through 8:00 AM on 1/19/2020.
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.
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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.
The most recent 6J tune-ups were completed on 12/6/2020 for Boiler#1 and on 11/15/2020 for Boiler#2.
1 reviewed the tune up records and they appeared to be complete.
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.
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 2D.1111 and NESHAP Subpart 6J.
2D.1111 "Maximum Achievable Control Technology"
Subpart ZZZZ-NESHAP for Stationary Reciprocating Internal Combustion Engines
Specific Condition A.H.
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The 2 engines have bee were sold in November of 2019 and removed from the property.
2D.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.No complaints were
logged into the I Beam database during this timeframe 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. I did
discuss this with Ms. Weller, and we agreed to do it next year if the Covid 19 restrictions have been lifted.
I recorded this as a"brief' 112R inspection in I Beam.
"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.
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