AQ_F_0800081_20190306_CMPL_Malf-Det

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ROY COOPER NOATH CAROLINA
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MI HAEL ,RE AN
sec,ejary
M€ HAEL ABRA ZINSKAS
March 6, 2019
Mr. Brett Elliott, General Manager
Valley Proteins—Lewiston Division
PO Box 10
Lewiston-Woodville,NC 27849
SUBJECT: Cross Flow Scrubber Fan Malfunction
NCAC 15A 2D.0535 and 2Q.0508(f)(2)
Permit Condition 3. I. A.
Valley Proteins, Inc.
Lewiston, Bertie County,North Carolina
Air Permit No. 03085T32, Facility ID: 0800081, Fee Class: Title V
Dear Mr. Elliott:
On February 25, 2019 this office received your February 23, 2019 email which documented
the crossflow scrubber fan motor failed at 2:00 PM on February 23, 2019 and repairs were
initiated immediately. On February 23, 2019 your follow-up email documented that repair was
completed and the scrubber was back in operation six hours later at 8:00 PM.
The notifications meet the requirement in your Air Permit pursuant to 15A NCAC 2Q
.0508(f)(2). The written notification of the excess emissions incidents also satisfies the
requirements of 15A NCAC 2D .0535(c), and will be considered by this Division a malfunction
as defined in 15A NCAC 2D .0535 (a)(2)which states,
"Malfunction"means any unavoidable failure of air pollution control equipment,process
equipment, or process to operate in a normal and usual manner that results in excess
emissions. Excess emissions during periods of routine start-up and shut-down of process
equipment are not considered a malfunction. Failures caused entirely or in part by poor
maintenance, careless operations or any other upset condition within the control of the
emission source are not considered a malfunction. "
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Mr. Elliot
March 6, 2019
Page 2 of 2
If you have any questions or concerns regarding this matter,please feel free to call Betsy
Huddleston or me at(252) 946-6481.
Sincerely yours,
Robert P. Fisher, Regional Supervisor,
Division of Air Quality, NCDEQ
RPF
c: Washington Regional Office
DAQ Washington Regional Office-Documents\ Facilities\Bertie08\00081\20190306 Malfunction Determination.docx

_.
NC DAQ Excess Emissions Form Date: 3/yjZol g
Based on the information that the facility submits, the Division will determine if a
malfunction has occurred. This reporting requirement does not allow the operation of the
facility in excess of Environmental Management Commission Regulations. Continuing to
operate the facility in this manner is at the facility's own risk.
As required by 15A NCAC 2D.0535,"Excess Emissions Reporting and Malfunctions"(f), "The owner or operator of a
source of excess emissions which last for more than four hours and which results from a malfunction;a breakdown of
process or control equipment or any other abnormal conditions,shall:(1)notify the director or his designee of any such
occurrence by 9am of the next business day of becoming aware of the occurrence."
Title V facilities are required to report deviations within one business day and submit a written report within two business
days after the deviation pursuant to 15A NCAC 2Q.0508(f)(2).
Complete this Information
(A) Name and location of the facility: yall e4 Pi'a fB>h5
(B) Equipment involved and the nature and cause of the excess emissions/ alfunction deviation:
see f�<a � t'rna�ls CYbdSrClow gr_rub or , N,-chanrr..l trr/w-e ear,
A/0 SRe 4-Ae �1,2fa�& bra 'TUt�ljnn.
(C) The time/date the event was first observed: 2:6t PM 2
Z� 3�y61', (Y�1 t cte d ew— 4
j (D) The expected duration: Cnaed "�.6b PM ZJZ3/�19
(E) An estimated rate of emissions(if known): V6C emisSlo»S d,o917lb1lon Cpyrin)/eti1 I?2vYRG/le7
j . 0,0917(220d-r75) v 26F•G /b5 (_ayifrat/,4 VO6 avow" C)01, Can}rot ,5o UnCart'rvllec� N
(F) A written report*is required to be submitted to the Regional Supervisor.In accordance with 15A NCAC 2D 7A3 lbs
.0535(f)(3)the report is to include the following information:
(1) name and location of the facility,
(2) identification or description of the processes and control devices involved in the malfunction or breakdown,
(3) the cause and nature of the event,
(4) time and duration of the violation or the expected duration of the excess emission if the malfunction or breakdown
has not been fixed,
(5) .estimated quantity of pollutant emitted, -
(6) steps taken to control the emissions and to prevent recurrences and if the malfunction or breakdown has not been
fixed,steps planned to be taken,and -
(7) any other pertinent information requested by the director.
*If the company is Title V with a federal permit,the written report is required to be submitted within 2 business days.
All reports of deviations from permit requirements must be certified by the responsible official.
*For non-Title V facilities,the written report is required to be submitted within 15days.
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Version 1.1-10119104 j
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For DAO use:
Name of Notifrer: y `'Ill o// Telephone Number: 7�y'7�g`gjJ7 Z
Received by: fs AyOl� Date/TimeReceived: 21Z3 2atcf 9SOP11"
Comments: 13rcH Gava/ IfV /�"? Cmull ':�Oljwsg4 r?ms S/.ba; `lome 30 Oli�n�
Follow-up Written Notification Received: yes 2,12212415 If1o:r(o P/p ha 'e1nal!6fnytZ�zs�Lo1 q
and reviewed by: 92 cy XluwlPS4o7^
Comments•
Final review by Supervisor: I V "— Date:
Decision: Malfunction approved for these circumstances: V Yes No
Comments : L: 1 t 11 o f�U i n( ti t✓ g„�
IG
cc:Regional Facility File
Central Files,RCO
Y/N Compliant with reporting Timeliness and Certification?
If the company is Title V with a federal permit,the written report is required to be submitted within 2 business days.All
reports of deviations from permit requirements must be certified by the responsible official.
For non-Title V facilities,the written report is required to be submitted within 15 days.
Y/N ...the Director shall consider,along with any other pertinent information,the following:*
I
/ (1)The air cleaning device,process equipment,or process has been maintained and operated,to the maximum extent
racticable, consistent with good practice for minimizing emissions; y
(2)Repairs have been made expeditiously when the emission limits have been exceeded; ho llfri 1- '11 S e-Qnh-01ly
(3)The amount and duration of the excess emissions,including any bypass,have been minimized to maximum extent
practicable;
4 All practical steps have been taken to minimize the impact of the excess emissions on ambient au quality;
5 The excess emissions are not p art of a recurring pattern indicative of inadequate design,operation,or maintenance;
/ (6)The requirements of Paragraph(f)of this Rule have been met;and
ni p, (7)If the source is required to have amalfunction abatement plan,it has followed that plan.
/ Excess emissions caused by malfunctions from this source were less than 15 percent of the operating time during the
calendar year. No hurn2ucaP lrr rN ?CatiVo vat CO-P re r
# Additional Concern:
How many times before has this source experienced this type of malfunction?
*Ref;NCAC D-.0535 Excess Emissions Reporting And Malfunctions

Huddleston, Betsy
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From: Huddleston, Betsy
Sent: Tuesday, March 05, 2019 3:23 PM
To: Fisher, Robert
Subject: Valley Proteins Crossflow Scrubber Fan Malfunction History
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I did not see any malfunctions documented other than for the crossf low scrubber fan. Malfunctions were reported and
evaluated for the following dates:
10/04/2018-10/07/2018 "
11/23/2018(5 hrs)____U 0 a
8/28/2018-9/03/2018 A-w
8/23/2018-8/26/2018
There were non malfunction records in my email or in Sharepoint for 2016-2017
The next one back occurred from 12/7/2015-12/9/2015
Betsy Huddleston i4
EwL-ownewdEngimer
Dicasian of Air Quaht�,ttuashmgtonRegional Office
s 252.948 3335(Office) 043 tip' on Square IhII
252.975.3716(Fax) 1Washin�tm NC 27889
Betsy.Huddleston,, mdemr.go
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Huddleston, Betsy
From: Huddleston, Betsy
Sent: Monday, February 25, 2019 12:47 PM
To: Jones, Van
Subject: RE: [External] FW: Scrubberfan Lewiston
r
An email is fine for notification. Brent supplied what I need to know (the email didn't go through due to spelling error in
my name). I'll run the information by Rob Fisher, and let you know if he has anything to add.
-----Original Message-----
From:Jones,Van <[e-mail]>
Sent: Monday, February 25, 2019 11:55 AM
To: Huddleston, Betsy<[e-mail]>
Subject: [External] FW:Scrubber fan Lewiston
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to repo [e-mail]<mailto:repo [e-mail]>
Email he sent after repairs were made.
-----Original Message-----
From: Elliott, Brett
Sent: Saturday, February 23, 2019 10:56 PM
To: [e-mail]
Cc: Haynes, Matthew;Jones,Van
Subject: Scrubber fan Lewiston
Betsy the repairs where made on the scrubber fan at 8:00 pm and we are back up and running. Thank you. k
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The information transmitted herewith is confidential, proprietary information for use only by the addressee to whom it
was supplied. This information is not to be disclosed to any person or entity not employed by the addressee company,
and requiring the information to perform theirjob without the express written consent of Valley Proteins, Inc.
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Huddleston, Betsy
From: Jones,Van <[e-mail]>
Sent: Monday, February 25, 2019 11:54 AM
To: Huddleston, Betsy
Subject: RE: [External] Lewiston
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to [e-mail]<mailto:[e-mail]>
Okay. Brett told me he mailed you twice Saturday. Once when it went down and again when repaired. Is mail
satisfactory or do you prefer a letler?
-----Original Message-----
From: Huddleston, Betsy [mailto:[e-mail]]
Sent: Monday, February 25, 2019 11:38 AM
To:Jones, Van
Subject: RE: [External] Lewiston
Hi Van,
This is the first I've heard of a malfunction. I'll need information on when it occurred,what exactly went wrong, what
was repaired, and how long it was down.
-----Original Message-----
From: Jones,Van <[e-mail]>
Sent: Monday, February 25, 2019 9:54 AM
To: Huddleston, Betsy<[e-mail]>
Subject: [External] Lewiston
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CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an
attachment to [e-mail]<mailto:[e-mail]>
Betsy, what further notification do you need from us on the fan malfunction Saturday evening?
The information transmitted herewith is confidential, proprietary information for use only by the addressee to whom it
was supplied. This information is not to be disclosed to any person or entity not employed by the addressee company,
and requiring the information to perform theirjob without the express written consent of Valley Proteins, Inc.
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I
The information transmitted herewith is confidential, proprietary information for use only by the addressee to whom it j
was supplied. This information is not to be disclosed to any person or entity not employed by the addressee company,
and requiring the information to perform theirjob without the express written consent of Valley Proteins, Inc.
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Huddleston, Betsy
From: Jones,Van <[e-mail]>
Sent: Monday, February 25, 2019 11:55 AM
To: Huddleston, Betsy
Subject: [External] FW: Scrubber fan Lewiston
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to [e-mail]<mai Ito:repo [e-mail]>
Email he sent after repairs were made.
-----Original Message-----
From: Elliott, Brett
Sent: Saturday, February 23, 2019 10:56 PM
To: [e-mail]
Cc: Haynes, Matthew;Jones,Van
Subject: Scrubber fan Lewiston
Betsy the repairs where made on the scrubber fan at 5:00 pm and we are back up and running.Thank you.
The information transmitted herewith is confidential, proprietary information for use only by the addressee to whom it
was supplied. This information is not to be disclosed to any person or entity not employed by the addressee company,
and requiring the information to perform theirjob without the express written consent of Valley Proteins, Inc.
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Y]
Huddleston, Betsy
From: Jones, Van <[e-mail]>
Sent: Monday, February 25, 2019 11:55 AM
To: Huddleston, Betsy
Subject: [External] FW: Cross flow scrubber fan
Here is what he sent Saturday.
From: Elliott, Brett
Sent: Saturday, February 23, 2019 4:50 PM
To: '[e-mail]'
Cc: Haynes, Matthew; ]ones, Van
Subject: Cross flow scrubber fan
Betsy the Lewiston Plant had a mechanical failure on our cross flow scrubber fan at 2:00 pm today. We are in the
process of making repairs and will update you when the unit is back in service.Thank You
Brett Elliott
General Manager
Valley Proteins Lewiston
Office: (252)-348-2381 ext. 35117
Cell Phone: [phone]
E-Mail: BE [e-mail]
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The information transmitted herewith is confidential,proprietary information for use only by the addressee to whom i
it was supplied. This information is not to be disclosed to any person or entity not employed by the addressee
company, and requiring the information to perform their job without the express written consent of Valley Proteins,
Inc.
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