AQ_F_0400034_20191211_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Fina
ville Regional Office
AIR QUALITY roteins,Inc.-Wadesboro Division
ility ID 0400034
Inspection Report /FIPS:Anson/007
Date: 12/17/2019
Facility Data Permit Data
Valley Proteins,Inc. -Wadesboro Division 06467/T18
656 Little Duncan Road 10/3/2011Wadesboro,NC 28170 s 9/30/2016Lat: 35d 2.1192m Long: 80d 4.9683m tatus Title VSIC: 2077/Animal And Marine Fats And Oil Status ActiveNAICS: 311613/Rendering and Meat Byproduct Processing t Permit Application(s)TV-Renewal
Contact Data Program Applicability
Facility Contact 7tt =
Technical Contact SIP/Title V
MACT Part 63: Subpart 6J
James Hodges Maert Vogler NSPS: Subpart Dc
Environmental Manager Geector of
[phone] (70ironmental Affairs
0)877-2590
Compliance Data
Comments:
Inspection Date 12/11/2019
C/ � Inspector's Name Jeffrey D. Cole
Operating Status Operating
Inspector's Signature:
Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: On-Site Inspection Result Compliance
r
Total Actual emissions i TON /YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2018 0.1300 0.1400 25.40 17.16 21.34 0.1300 914.45
2017 0.2400 0.1900 24.27 15.96 19.85 0.2400 849.02
2016 0.2200 0.1800 25.13 17.75 20.71 0.2200 886.68
*Highest HAP Emitted(inpounds)
Five Year Violation History:None
Date Letter Type Rule Violated Violation Resolution Date
Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested

L MACT/GACT: The facility is subject to GACT 6J,though this is not currently in the permit. 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 1 September 2018. A copy of the biennial certification was on-site,and was prepared
on time.
II. DIIZECTIONS TO SITE: From FRO,take US 401 South through Wagram. South of Wagram,take
Old Wire Road(NC 144)to US74. Follow US 74 west through Wadesboro, and turn right(north)
onto US52. Go a few miles,pass Triangle Brick on right, go '/4 mile, and the entrance to the Valley
Protein plant is on the right. Proceed down the road to the driveway to the office building on the left
side of the parking lot/driveway.
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—140 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 11 December 2019,I,Jeffrey Cole of DAQ FRO, arrived at Valley
Protein to conduct an air quality compliance inspection. I met with James Hodges,Environmental
Manager. Mr. Hodges reviewed the FacFinder data and noted that no changes were necessary. Mr.
Hodges stated that the company has more employees this year as they have recently bought a
competing rendering company and absorbed their workforce and customers. The plant has not had its
natural gas supply curtailed since the last inspection. 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.
All of the facility's records 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 1 September 2019. After reviewing
the facility's records, Mr.Hodges and I toured the facility.
The facility was rendering any 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—18 hours. All scrubbers were operating at the time 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-1 and B-

2 were set to pin position 2 while Boiler 3 was set at pin position 1 during the inspection. When the
boiler is in"pin position 1," 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. No odor was noted on
the nearby roads when leaving the facility.
VI. PERMITTED EMISSION SOURCES:
Sd ce tss�orl arcev�ce Gp a �ceDesa IF
TD Nu �
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
B 2 input rate each) N/A N/A
Both operating on natural gas at low
fire(pin position 2);both boilers were
operating as control devices—0%
opacity.
One natural gas/No.2 fuel oil/saleable
fat-fired boiler(48.4 million Btu per
B-3 hour heat input) N/A N/A
NSPS Operating on natural gas at low fire
(pin position 1);not operating as
control device—0%opacity.
One natural gas/No.2 fuel oil/No. 6
fuel oil/On Specification recycled No.
B 4 4 equivalent fuel oil/saleable fat-fired N/A N/A
boiler(33.5 million Btu per hour heat
input)
Not Operating
FB-5One natural gas/No.2 fuel oil/No. 6
fuel oil/On Specification recycled No.
4 equivalent fuel oil/saleable fat-fired
boiler(29.3 million Btu per hour heat N/A N/A
input)
No longer on site;moved to another
facility

C-5 One air cooled condenser
in series with
C-1 One venturi scrubber(minimum
scrubber liquid inlet pressure 9 psig)
with a
Mist eliminator
Feather and Blood Rendering process C-1 operating at II psig
consisting of:
E2,E3,E4- C-2 venting to One cyclone(60-inch diameter)with a
a,E4-b,E4- either Mist eliminator in series with a
c, E5-a,E5- a)Seven batch cookers CY-1 combination of three natural gas/fuel
b, and E6 HAVE BEENBEMOVED E9 CM-1 oil/saleable fat-fired boilers
b)One rotary steam tube dryer B-1 to B-3 or One packed tower scrubber(minimum
C-4 scrubber liquid inlet pressure 3 psig)
c)One feather hydrolyser Two natural gas/fuel oil/saleable fat-
fired boilers (B-1 and B-2)operating
d)One feather press as control devices; C-4 operating at
12 psig
E10 Not operating
C-3 One venturi scrubber(minimum
scrubber liquid inlet pressure 5 psig)in
series with
C-4 One packed tower scrubber(minimum
scrubber liquid inlet pressure 3 psig)
C-3 operating at 15 psig; C-4
operating at 12 psig
C-6 One air cooled condenser
in series with
C-1 One venturi scrubber(minimum
scrubber liquid inlet pressure 9 psig)
with a
El Mist eliminator
Rendering process consisting of: C-1 operating at 11 psig
One three stage slurry system
evaporative condenser cooker with post
heater forced circulation chamber on P' C-2 venting to One cyclone(60 inch diameter)with a
stage either Mist eliminator in series with a
CY-1 combination of three(3)natural
CM-1 gas/fuel oil/saleable fat-fired boilers
Not operating B-1 to B-3 or One packed tower scrubber(minimum
C-4 scrubber liquid inlet pressure 3 psig)
Two natural gas/fuel oilIsaleable fat-
fired boilers(B-I and B-2) operating
as control devices C-4 operating at
E18 One fluidizer tank 12 psig
Not operating C-3 One venturi scrubber(minimum
scrubber liquid inlet pressure 5 psig)in
series with
C-4 One packed tower scrubber(minimum
scrubber liquid inlet pressure 3 psig)
C-3 operating at 15 psig;C-4
operating at 12 psig

C-7 One air cooled condenser
in series with
C-1 One venturi scrubber(minimum
scrubber liquid inlet pressure 9 psig)in
series with a Mist eliminator
C-1 operating at 11 psig
E7 One 320U cooker C-2 venting to One cyclone(60 inch diameter)with a
either Mist eliminator in series with a
CY-1 combination of three natural gas/fuel
Not operating CM-1 oil/saleable fat-feed boilers
13-1 to B-3 or One packed tower scrubber(minimum
C-4 scrubber liquid inlet pressure 3 psig)
Two natural gas/fuel oil/saleable fat-
fired boilers (B-I and B-2) operating
ES as control devices;C-4 operating at
Press/centrifuge process 11 psig
C-3
Not operating One venturi scrubber(minimum
C-4 scrubber liquid inlet pressure 5 psig)in
series with One packed tower scrubber
(minimum scrubber liquid inlet
pressure 3 psig)
C-3 operating at 15 psig;C-4
operating at 12 psig
One,two stage,cross-flow type wet
scrubber,minimum scrubber liquid
Plant room air system inlet pressure 13 psig with mist
E22 Not operating C-8 eliminator,utilizing chlorine dioxide or
DuPont ActXone—ZA300HS
C-8 operating at 30 psig(Stage 1) and
30 psig(Stage 2)
VH. 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 lb/mmBtu for boilers B-1 and B-2, 0.318 lb/mmBtu for boiler B-3, 0.30 lb/mml3m
for boiler B-4, and 0.28 lb/mmBtu for boiler B-5.
APPEARED IN COMPLIANCE—The facility has only combusted natural gas, and some
saleable fat in 2016 The AP-42 emission factor for natural gas is 0.007 lhlmmBtu. Source
testing at the facility in April 2001 resulted in a PMemission factor of 0.05 lhlmmBtu while
combusting saleable fat.

B. 15A NCAC 2D .0516 SULFUR DIOXODE 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 facility fires natural gas exclusively, and will combust
saleable animal fat or fuel oil during testing and curtailment; there are 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 (10129118). The semiannual report was received on 7111119, 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-1 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 7111119, and indicated compliance.
D. 15A NCAC 2D.0524 NSPS 40 PART 60 SUBPART Dc—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. There
are 21,650 gallons of saleable animal fat and 19,773 gallons of No. 6 fuel oil on-site.
E. 15A NCAC 2Q .0317 AVOIDANCE OF PREVENTION OF SIGNIFICANT
DETERIORATION for SO2 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 are complete, and emissions appear to
be calculated correctly using the emission factors listed in the permit. The last semiannual report
shows SO2 emissions while firing natural gas totaled 0.17 tons from July 18 through June 19 and
CO emissions while firing natural gas total 23.46 tons from July 18 through June 19. In the most
recent 12 months (December 18 through November 19) records show SO2 emissions while firing
natural gas total 0.17 tons and CO emissions while firing natural gas total 24.13 tons.

F. 15A NCAC 2D .0501 EMISSION CONTROL STANDARD—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 COMPLL4NCE—The facility makes daily calculations of SO2 emissions based
on fuel combusted the previous day. Suter content of fuels is so low that average daily SOz
emissions are typically less than one pound.
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(11)No. E10),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°61,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 visible inspection, including all ductwork, and an
annual internal inspection of condensers and venturi/packed tower scrubbers.
APPEARED IN COMPLL4NCE—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. No recent issues have been uncovered during
inspections.
H. 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
1200 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.

APPEARED INCOMPLIANCE—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, I noted operating parameters 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 12 psig. The inlets
to crossflow scrubber C-8 (13 psig minimum) were operating at 30 psig(1'stage) and 30 psig
(2"d stage). The ORP values were observed to be +597mV(packed tower scrubber C4) and+754
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 on-site during
the inspection was—18 hours.
The facility has a rigorous cleaning and inspection regimen, which exceeds the permit
requirement and is completed weekly. Calibrations are completed monthly by Chemtreat, and the
required "ActXone"chemical was in use. All of the internal duct work including the inside of the
scrubbers were cleaned on 12101119.
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 Permittee shall report excess emissions in
accordance with 15A NCAC 21) .0535,and report any permit deviations quarterly.
APPEARED IN COMPLLANCE— Mr. Hodges is aware that the permit requires reports of
excess emissions and of deviations, and submits reports if required. Mr. Hodges stated that no
instances of excess emissions have occurred since the last inspection.
K. GENERAL CONDITION"P"—COMPLIANCE CERTIFICATION—The Permittee shall
submit a compliance certification annually no later than March I".
APPEARED IN COMPLIANCE—The facility's ACC was received on 01118119, and appeared
complete and accurate.
L. GENERAL CONDITION"X"—COMPLIANCE CERTIFICATION—The Permittee shall
submit an annual emission inventory for the previous year no later than June 301.
APPEARED INCOMPLIANCE—The facility's CY2018 AQEI was received on 06104119, and
appeared complete and accurate.

VIH. INSIGNIFICANT ACTIVITIES:
'Emission Source I,D. Emission Source Description
IE-21.1,IE-21.2,and IE- One load-out operation consisting of two track loadout bays in a building open on two
21.3 ends with tractor trailer truck overhead doors,and one railcar loadout open to the
atmosphere.
IE24.1,IE-24.2,and IE- One grinding operation consisting of three(3)hammermill/shaker screen systems in a
24.3 building open on two ends with tractor trailer truck overhead doors
IE-25 Chlorine dioxide generation and delivery system
REh1OVED FROM SITE
IX. NON-COMPLIANCE HISTORY SINCE 2010: No non-compliance issues noted.
X. RISK MANAGEMENT (112r): The facility does not store any subject chemical compounds in
quantities that would require a written Risk Management Program(RMP).
XI. CONCLUSIONS AND RECOMMENDATIONS:
Valley Proteins,Inc.—Wadesboro Division appeared to be operating INCOMPLL4NCE with their air
quality permit on 12/11/19.
PINK SHEET ADDITIONS:
- None.
/jdc