AQ_F_0400034_20210224_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: 03/15/2021
Facility Data Permit Data
Valley Proteins,Inc.- Wadesboro Division Permit 06467/T20
656 Little Duncan Road Issued 2/20/2020
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)TV-Significant,
TV-Significant
Contact Data
Facility Contact Authorized Contact Technical Contact Program Applicability
Gaz Thomas Gaz Thomas Matt Haynes SIP/Title V
MACT Part
General Manager General Manager District Environmental
[phone] [phone] Manager NSPS: Subpart
Dc
Subpart 6J
[phone]
% Compliance Data
Comments:
Inspection Date 02/24/2021
Inspector's Name Jeffrey D.Cole
Inspector's Signature: Operating Status Operating
Compliance Status Compliance-inspection
Action Code FCE
Date of Signature: //5/� Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
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
2017 02400 0.1900 24.27 15.96 19.85 0.2400 849.02
*Highest HAP Emitted inpounds)
Five Year Violation History:
Date Letter Tyne 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

1. MACT/GACT: The facility completed the one-time Energy Assessment on 07-08 November 2013,
submitted the NOCS on 03 June 2014, and is conducting boiler tune-ups semiannually with the last
tune-ups being performed on 25 October 2020. A copy of the biennial certification was on-site and was
prepared on time.
II. 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 (NC144)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''A mile,and the entrance
to the Valley Protein plant is on the right(656 Liftle Duncan Rd.)
III.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.
IV. 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—150 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.
V. INSPECTION SUMMARY: On 24 February 2021, 1, Jeffrey Cole of DAQ FRO, arrived at Valley
Protein to conduct an air quality compliance inspection. I conducted the records review in a large
conference room to comply with Covid-19 restrictions. I met with James Hodges, Environmental
Manager. Mr. Hodges reviewed the FacFinder data and noted that no changes were necessary. The
facility has not accepted any fuel oil in years, however there are 19,773 gallons of No. 6 fuel oil stored
on-site. There are also 21,650 gallons of saleable animal fat stored on-site. These storage totals have
not changed since the last inspection. Mr. Hodges noted that the Chlorine dioxide generation and
delivery system was still listed in the permit's insignificant/exempt activities list. A pink sheet note
will be added to request the permit engineer to remove the Chlorine dioxide generation and delivery
system from the insignificant activities list as the system has been removed.
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 25 October 2020. After
reviewing the facility's records,Mr. Hodges left to tour the facility and used his cell phone to show me
the gauges that I needed to see.

The facility was rendering material during the inspection. At the time of the inspection,the facility's
process computer showed the longest duration that any material had been waiting on site was-4 hours.
All scrubbers were operating at the beginning of the inspection. The facility boilers ES ID Nos. B-1,
B-2 and B-3 were all operating on natural gas,with zero opacity noted. Boilers B-I and B-2 were set to
pin position 2 while Boiler 3 was set at pin position I during the inspection. When the boiler is in"pin
position I,"it is considered low-fire, and the damper to the boiler is completely closed, meaning all
vapor is directed to the packed tower scrubber. "Pin position 2"and higher is considered mid to high
fire,and the damper to the boiler is fully open while the scrubber damper is completely shut. While in
this state,the scrubber is idle and is in standby in case vapors need to be directed back away from the
boilers. While the scrubber is idling,the flow rate,water pressure, chemical concentration level and
ORP> 300 mV are maintained.
All scrubbers were operational, and their gauge readings(flow rate/pressure, ORP)were within the
permit limits with the exception of the two stage, cross-flow type wet scrubber(CD ID No. C-8). At
-10:50 AM, as Mr. Hodges was on the roof heading towards the 2 gauges that show the flows to the
2 stages of the scrubber,the Stage 1 piping came lose and water was pouring on the roof. The
maintenance team was called shortly after the pipe came loose and repairs were completed by
11:30 am. While the water was pouring on the roof,the pressures of Stage 1 were at 0 psig; and Stage
2 was at 19 psig. It turns out that, on Sunday 02/21/21,the company had replaced the PVC pipe from
the scrubber makeup water tanks to both stages on C8 Cross flow scrubber. In repairing the pipe on the
day of the inspection,the piping was glued, and bolts put in the pipe to ensure it doesn't come loose
again. After the repair the inlets to cross-flow scrubber C-8 (13 psig minimum)were operating at 30
psig(I st stage) and 30 psig(2nd stage). I reminded Mr. Hodges that he needed to send in a quarterly
deviation report and note the deviation on his upcoming semi-annual report and the next ACC. No odor
was noted on the nearby roads when leaving the facility.
VI. PERMITTED EMISSION SOURCES:
pg
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at I '1}+ ?,Is,_+ E1tl788In7�, 1hk +�tSi,Sk1191E -c�' r .0' wv - 161� Y14S�$`,` as
4
RKE__y Two natural gas/No.2 fuel oil/No. 6
fuel oil/On Specification recycled No.
4 equivalent fuel oil/saleable fat-fired
B-1 and ` boilers(33.0 million Btu per hour heat
i input rate each) N/A N/A
B-2 ( Both e perafdng on natural gees to low � !
fire(pin position 2):both hoilers mere '
op3eratdng as control devices-0%
One natural gas/No.2 fuel oil/saleable C
fat-fired boiler(48.4 million Btu per
1
B-3 j hour heat input) N/A N/A
NSPS Operating on natant gas eft loco fire
(pur position 1);not operating as
1 control derice--0%opuclty, __y:.

One natural gas/No.2 fuel oil/No.6
` fuel oil/On Specification recycled No. I
[ 4 equivalent fuel oil/saleable fat-fired
B-4 boiler(33.5 million Btu per hour heat N/A N/A j
input) '...'s
Operfrt&tg_
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
boiler(29.3 million Btu per hour beat N/A I N/A
I input) ! j
[ No longer on.sing:moved is another j
Feather and Blood Rendering process
j consisting of.
E
E6 One rotary steam tube dryer C-5 One air cooled condenser
in series with
E9 One feather hydrolyser C-I One venturi scrubber(minimum
j scrubber liquid inlet pressure 9 psig)
with a
Mist eliminator
C-C operating at tC p.stg
C-2 venting to i One cyclone(60-inch diameter)with a
either Mist eliminator in series with a
CY-1 i combination of three natural gas/fuel oil
CM-1 /saleable fat-fired boilers
B-I to B-3 or One packed tower scrubber(minimum
C-4 scrubber liquid inlet pressure 3 psig)
Two natural gay4iiel oiUwdeable}at
-fired fioilers(P#-7 and B-2) opea'aPing
as control derice ('-d o�lerarirrg of
7pstg 4
E 10 One feather press C-3 One venturi scrubber(minimum
scrubber liquid inlet pressure 5 psig)in
Not operateng series with
C-4 One packed tower scrubber(minimum
scrubber liquid inlet pressure 3 psig)
C"-3 operating at 15 psig; t-4 C
_ _ operating. -- al 7 psig
....
i
El 1 Rendering process consisting of: C-6 One air cooled condenser
One three stage slurry system ( in series with
evaporative condenser cooker with post C-1 One venturi scrubber(minimum
heater forced circulation chamber on Ill € scrubber liquid in pressure 9 psig)
stage with a
j Mist eliminator
C?perrttirt}� C'-d operating at 9l pxig
C-2 venting to One cyclone(60 inch diameter)with a
either Mist eliminator m series with a

CY-IJ combination of three(3)natural j
CM-1 ( gas/fuel oil/saleable fat-fired boilers
B-1 to B-3 or ! One packed tower scrubber(minimum
j C-4 scrubber liquid inlet pressure 3 psig) !
T'wo natural gas/fuel oil/saleable fiat
fired boilers (B-1 and 8-2) operatha,
I as control devices;4"-4 operating at
7psag
I � �
E18 One fluidizer tank C-3 One venturi scrubber(minimum
scrubber liquid inlet pressure 5 psig) in
I Vol operating '. ii series with
I
C-4 One packed tower scrubber(minimum
scrubber liquid inlet pressure 3 psig)
C=3 operating at l5psi,,: C-4
arperating at 7 psig
E7 One 320U cooker C-7 One air cooled condenser
in series with
j C-1 One venturi scrubber(minimum
Operating I scrubber liquid inlet pressure 9 psig)in
series with a Mist eliminator I
C-1 operadng at H psig
C-2 venting to .� One cyclone(60 inch diameter)with a
I either = Mist eliminator in series with a I
CY-1 combination of three natural gas/fuel
CM-1 i. oil/saleable fat-fired boilers
B-1 to B-3 or One packed tower scrubber(minimum
i I C-4 scrubber liquid inlet pressure 3 psig)
Tiro natural gas/f iel oil/saleableJ'at
i
-fired hailers(H-1 and B-2)operating
as control devices;C-4 operating at
7 psig
i
1
E8 I Press/centrifuge process j C-3 1 One venturi scrubber(minimum
scrubber liquid inlet pressure 5 psig)in
.-Not operrian,> C-4 j series with One packed tower scrubber
j (minimum scrubber liquid inlet
pressure 3 psig)
C-3 operating at l5psil;t C-f
i operating rat 7 psig
On two stage,cross-flow type wet j
scrubber,minimum scrubber liquid
i Plant room air system inlet pressure 13 psig with mist
E22 C7perrartrtg C-8 eliminator,utilizing chlorine dioxide or
1 a sulfate-based odor oxidizing solution.
1ficrtltepipingryasrepairedScrubher :I
3 € C-8 was shown operating at 30 psi,
j (Stu ge 1) raid 30 psig (Stage 2)
9

VIL APPLICABLE AIR QUALITY REGULATIONS:
A. 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 Ib/mmBtu for boilers B-1 and B-2,0.318 Ib/mmBtu for boiler B-3,0.30 Ib/mmBtu for
boiler B-4, and 0.28 Ib/mmBtu for boiler B-5.
APPEARED INCOMPLIANCE—The facility has only combusted natural gas since 2017. The
last time saleable fat was combusted was in 2017. The AP-42 emission factor for natural gas is
0.007lb/mmBtu. Source testing at the facility in April2001 resulted in a PMemission factor ofO.05
lb/mmBtu while combusting saleable fat. The AP-42 PMemission factor for No. 4 fuel oil is 0.05
lb/mmBtu. The AP-42 PMemission factorfor No. 6 fuel oil is 0.061b/mmBtu.
B. 15A NCAC 2D .0516 SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
—Sulfur dioxide emissions from the facility's boilers shall not exceed 2.3 Ib/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 COMPLLANCE—The facility fires natural gas exclusively and will combust
saleable animal fat or fuel oil only during testing and curtailment; there are still 21,650 gallons of
saleable animal fat and 19,773 gallons of No. 6 fuel oil on-site. No saleable animal fat has been
combusted since January 2017 during curtailment. No fuel oil has been combusted since the last
inspection (12111119). The semiannual report was received on 1120121 and indicated compliance.
C. 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—Boilers B-1, B-2, and B-3 were operating on natural gas with
Boilers B-I and B-2 in mid to high fire mode (pin position 2) and Boiler B-3 in low fire mode (pin
position 1)with zero visible emissions during the inspection. 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 1120121 and indicated compliance.
D. 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—No fuel oil has been combusted since the last inspection
(12111119). There are still 21,650 gallons of saleable animal fat and 19,773 gallons of No. 6 fuel oil
on-site. It appears that NSPS Dc requires records of each fuel used in the boiler on a monthly basis. A
pink sheet note will be added as follows: "The permit engineer needs to review 40 CFR 60.48c(g)(2)
(Listed in Permit T20 Stipulation 2.I.A.4 fi as it appears to require records of each fuel used in the
boiler on a monthly basis. This would include natural gas, saleable fat, 42, #4, and 96 fuel oil. "

E. 15A NCAC 2Q.0317 AVOIDANCE OF PREVENTION OF SIGNIFICANT
DETERIORATION for S02 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 animal fat oil 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 emission factors listed in the permit. The last
semiannual report shows SOz emissions while firing natural gas totaled 0.18 tons from January
2020 through December 2020 and CO emissions while firing natural gas total 24.92 tons from
January 2020 through December 2020. In the most recent 12 months (February 2020 through
January 2020) records show S02 emissions while firing natural gas total 0.18 tons and CO
emissions while firing natural gas total 25.59 tons.
F. 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 S02 emissions based
on fuel combusted the previous day. Mr. Hodges sent me an email after the inspection noting that
the su fur dioxide emitted from boilers B-1, B-2, B-3, B-4 and B-5 on 2124121 was only 1.1 pounds.
G. 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. El0), rendering process(ID No. El), and
fluidizer tank(ID No.E10), 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 Ib/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—During the inspection, all control devices were operating.
Control devices are typically inspected more frequently than is required; internal inspections are
conducted weekly for all control devices during cleaning with the exception of the,facility's
condensers which are inspected internally on a semiannual basis. Monthly external inspections
are conducted and recorded as required Repairs to the one scrubber(C-8) that lost its water feed
during the inspection were completed within 2 hours and no PM emissions were observed during
the repair.
H. 15A NCAC 2D .0539 ODOR CONTROL FOR FEED INGREDIENT MANUFACTURING
PLANTS—The Pennittee shall ensure that odorous emissions are controlled by control devices as
listed in the pen-nit 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
Pennittee shall monitor the boiler operating parameters once per day for confirmation of boiler
operation above low fire if being used for odor control. The Pennittee 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—I noted a slight rendering odor at the street as I entered the
premises. The only noticeable odor on-site was directly outside the rendering buildings. During
the inspection, Mr. Hodges toured the plant with his cell phone and showed me the gauges and
controls to note the operatingparameters on the control equipment as follows: Venturi C-1 (9 psig
minimum) was operating at 11 psig, venturi C-3 (5 psig minimum) was operating at 15 psig. The
packed tower scrubber C-4(3 psig minimum) was operating at 7 psig.
During the inspection at—10:50 AM, the Stage I piping came lose and water was pouring on the
roof. The maintenance team were called shortly after the pipe came loose and repairs were
completed by 11:30 am. While the water was pouring on the roof, the pressures of Stage I were at
0 psig; and Stage 2 was at 19 psig. It turns out that, on Sunday 02121121, the company had
replaced the PVC pipe from the scrubber makeup water tanks to both stages on Cross-Flow
Scrubber C8. In repairing the pipe on the day of the inspection, the piping was glued, and bolts put
in the pipe to ensure it doesn't come loose again. After the repair the inlets to cross-flow scrubber
C-8(13 psig minimum) were operating at 30 psig(1st stage) and 30 psig(2nd stage). I reminded
Mr. Hodges that he needed to send in a quarterly deviation report and note the deviation on his
upcoming semi-annual report and the next ACC.
The ORP values were observed to be +551 in(Packed Tower Scrubber C4)and+425 in(Stages
I and II of Cross-Flow Scrubber C8). The pressures and ORPs are monitored and recorded each
shift in addition to being continuously logged electronically; all showed compliance. 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. Storage of material while
on-site is tracked electronically, and the longest any material was onsite during the inspection was
—4 hours. The company has a handwritten login the scale house where we record any loads that go
over eighteen hours. Eighteen hours is their warning that something has to happen with the load
quickly. If a load reaches the eighteen hour mark the General Manager and Plant Manager is
notified to ensure the load is dealt with. They have not logged anything in this book in over two
years.

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 of the internal duct work including the
inside of the scrubbers was cleaned on 11115120.
I. 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—Zero recycled No. 4 has been purchased or combusted since
2005. There is no recycled oil on-site.
J. GENERAL CONDITION"I"—REPORTING REQUIREMENTS FOR EXCESS
EMISSIONS AND PERMIT DEVIATIONS—The Pennittee 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 the incident on 27 February
2020 when they discovered that the fan on Venturi Scrubber C-I failed and they opened across
connect plenum so that non-condensable odors were being treated in the cross-flow scrubber, ID
No. C 8, until the fan on C-1 was replaced, and that they were not aware of any excess emissions
during this event. This cross connect is not allowed in their current permit. This event resulted in
a Notice of Violation for GS 143-215.108A- Operating Without a Permit. The company sent a
quarterly deviation report dated 3119120 noting the deviation. The company submitted a permit
modification on 11116120 to allow for this cross-connection option.
K. GENERAL CONDITION"P"—COMPLIANCE CERTIFICATION—The Permittee shall
submit a compliance certification annually no later than March 1'.
APPEARED IN COMPLIANCE—The,facility's ACC was received on 02116120 and appeared to
show compliance.
L. GENERAL CONDITION"X"—ANNUAL EMISSION INVENTORY REQUIREMENTS—
The Permittee shall submit an annual emission inventory for the previous year no later than June
30t".
APPEARED IN COMPLIANCE—The facility's CY2019 AQEI was received on 04114120 and
appeared complete and accurate.
M. 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 (RMP).

N. 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. Shoe stated that the facility had any dust or odor complaints
since our last inspection. FRO has also not received and dust complaints about this facility.
VIII. INSIGNIFICANT ACTIVITIES-
ElIF�SSiUII r."�`LQtIi'C$ Ds v k19sa6u,54Ucce 1T@& RMA1 j, e � 4 r
,i . . }ka..._
IE-21.1, IE-21.2,and One load-out operation consisting of two truck loadout bays in a building open on two
IE-21.3 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 systems in a
IE-24.3 buildin o en on two ends with tractor trailer truck overhead doors
IE-25
;1$tD,'Ls t) Chlorine dioxide generation and delivery system
ttt: F'tgfyLt
IX. 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. Staff turnover contributed to the violation
and non-response;therefore, enforcement will not be 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 away that was not permitted.
X. CONCLUSIONS AND RECOMMENDATIONS:
Valley Proteins, Inc.—Wadesboro Division appeared to be operating INCOMPLIANCE with their air
quality permit on 02/24/21.
PINK SHEET ADDITIONS:
• Request the permit engineer to remove the Chlorine dioxide generation and delivery system
from the insignificant activities list as the system has been removed.
• The permit engineer needs to review 40 CFR 60.48c(g)(2)(Listed in Permit T20 Stipulation
2.1.A.41)as it appears to require records of each fuel used in the boiler on a monthly basis.
This would include natural gas, saleable fat, 42, #4, and#6 fuel oil.
/jdc