AQ_F_0800081_20190903_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Washington Regional Office
AIR QUALITY Valley Proteins-Lewiston Division
NC Facility ID 0800081
Inspection Report County/FIPS:Bertie/015
Date: 10/07/2019
Facility Data Permit Data
Valley Proteins-Lewiston Division Permit 03085/T32
222 Griffins Quarter Road Issued 1/29/2018
Lewiston-Woodville,NC 27849 Expires 12/31/2022
Lat: 36d 8.4040m Long: 77d 13.4680m Class/Status Title V
SIC: 2048/Prepared Feeds Nec Permit Status Active
NAILS: 311119/Other Animal Food Manufacturing Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP/Title V
Brett Elliott Brett Elliott Robert Vogler MACT Part 63: Subpart 6JNSPS: Subpart Dc
General Manager General Manager Director of
[phone] [phone] Environmental Affairs
[phone]
Compliance Data
Comments: The facility appeared to operate in compliance with the permit
conditions and applicable regulations at the time of the inspection. Inspection Date 09/03/2019
Inspector's Name Betsy Huddleston
Inspector's Signature: Operating Status Operating
P 'ru� Compliance Code Compliance-inspection
IY Action Code FCE
On-Site Inspection Result Compliance
Date of Signature:
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2018 0.3800 0.1500 6.74 22.86 5.62 0.3400 240.89
2017 0.3400 0.1600 5.04 20.22 4.18 0.3000 178.90
2016 0.3800 0.0700 5.22 23.49 4.37 0.3400 187.15
*Highest HAP Emitted inpounds)
Five Year Violation History:None
Performed Stack Tests since last FCE:None
Directions
Valley Proteins, Inc. operates a chicken rendering plant located on Highway 308 West,Lewiston Woodville,
Bettie County. Directions from Washington Regional Office are as follows:
• Follow Hwy 17 N to Windsor, and go through the first stoplight(funeral home on the right).
• At the third stoplight,turn left onto Highway 308 West.
• Stay on Highway 308 to Lewiston Woodville. The plant is located behind the Perdue chicken
processing plant which is on the left side of the road just north of the town.
• Turn left at the Perdue chicken plant and continue down the road past Perdue.
• There is a W.E. Partners facility at the entrance to the rendering plant, so drive past it and go
to the brick office building.

Safety Concerns
• There are trip and slip hazards. The floor is wet,and there are eye and floor level equipment.
• There are tractor trailers frequently coming and going from the facility.
• Hearing protection,hard hat, safety glasses and safety shoes are required.
Permit History
The 5-yr permitting history for the rendering plant is provided as follows:
• A tax certification was issued to Valley Proteins on 8/27/2014 for the scrubbers,condensers and
the common cooling tower(which only serves the condensers), as well as their appurtenances.
Valley Proteins purchased the Perdue rendering plant in the fall of 2012, and this was their first
tax certification for the Lewiston facility. They reported that Perdue had previously applied for
tax certification for this equipment,but I could find no evidence in the DAQ file that Perdue had
submitted any previous tax certification applications.
• T31 was issued on 6/17/2015 for minor changes to the permit item list. The"poultry meal storage
silos"were changed to"meal storage silos,"and the control devices for the silos were removed.
The meal storage silos(ID Nos. ES-I I through ES-16)and the poultry meal loadout(ID No. ES-
19)were redesignated as insignificant activities based on revised emission factors. The"poultry
meal loadout"label changed to"meal loadout."
• T32 was issued on 1/29/2018 for permit renewal. The truck load processing time limits were
updated in this permit revision per Session Law 2015-263.
• A tax certification was issued on 4/09/2018 for replacement of the framing for both the crossflow
and packed bed scrubbers.
• A tax certification was issued on 5/17/2019 for a new 66" Scrubber Fan. This was Valley
Proteins' third tax certification for the Lewiston facility.
Process Description
1. Meat/feather trucks dump at the receiving pad. There are three raw material bays(two are for meat
and one is for feathers). There is also a grease hopper that is used for recycling tank bottoms
(cleanout). The material is carried by conveyor and trash is removed. Bone is delivered in
refrigerated trucks. Bone waste is metered into the meat mix. Grease and blood are delivered and
unloaded from enclosed containers.
2. Blood is pumped to holding tanks. It is then sent to two centrifuges, cooked and added to the feathers
before going to the dryer.
3. Trailers are rinsed and sanitized. Time cards are punched when the trucks come onto the property
and again when the trucks are dumped. Time cards are also kept for bone, grease and blood loads.
4. The meat goes to the preheater or bypasses to the dual cooker. Most of the steam is usually provided
by the W.E. Partners boilers (Facility ID 0800107).
5. Meat is discharged from the preheater over a set of drainers to remove excess liquids(fat). The
drainer is hooded and ties into the press vent. The press and preheater vents are low pressure, so they
tie together and vent directly to the venturi scrubber and packed scrubber.
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6. Liquid/fat goes to the evaporators. Waste heat from the cookers, feather dryer,hydrolyzer flash and
chamber is used to heat the evaporators. There is an emergency vent on the evaporators. The fat
moisture level is reduced by about half,and then the liquid concentrate is pumped to the meat
cookers.
7. Meat conveys from the preheater to either cooker, but the#2 cooker does not require the use of the
preheater.
8. The cookers discharge into a set of drainers where fat is drained off and pumped over a screening
system. The fat is then pumped to a centrifuge to remove remaining particles. The solids from the fat
are conveyed back to the presses and then cookers.
9. The fat is lastly pumped to centrifuge and holding tanks for shipment.
10. The meat from the cookers goes to four meat presses.All meat is pressed down to a low percentage of
fat. The fat from the press goes back to the screen and centrifuge.
11. Presses#1 and#3 feed to a bin and then a grinder. Presses#2 and#4 also feed to a bin and grinder.
12. The meat(meal)goes through shakers and is conveyed to screens for sizing. It is then transferred to
silos for shipment. Oversized material from the screens is sent back to the grinders.
13. Feathers are processed separately from the meat product. They are transferred from the dump pad to
the hydrolyzer where they break down under pressure. They have a wet oatmeal appearance.
14. The feathers then go through a press where moisture is reduced by more than half. Blood is
centrifuged into a solid, and is metered into the feathers. The feathers are discharged into a flash
chamber,then to a blue-colored cooker(dryer)that is located between the two meat cookers.
Feathers are dried to very low moisture content. The hydrolyzer and feather cooker do not produce as
much condensate as the meat cookers.
15. The feather meal goes to a shaker screen and grinder that is located with the meat grinders. The
feather meal is then transferred to silos.
16. The cookers,hydrolyzer, flash chamber, and feather dryer all vent to the waste heat system before
venting to the venturi scrubber. The press and preheater emissions vent directly to the venturi
scrubber. From there all process emissions go to the packed scrubber. Process room air is pulled
under vacuum to a crossflow scrubber on the roof of the facility.
17. The meal loadout is located in a 3-sided building. Meal is sold to animal feed companies. Fat is sold
for re-blending in feed and as an ingredient in products such as cosmetics. Some nutrient additives
are applied during the rendering process according to client specification.
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The sources and control devices at the facility are listed on the permit in the following format.
Emission Control
Source ID No. Emission Source Description Device Control Device Description
ID No.
ES-8 and Two natural gas/saleable CD-10F One packed bed scrubber(288 to 575 gallon
ES-9 animal fat/No. 6 fuel oil-fired per minute normal operating range)utilizing
boilers(84 MMBtu/hr max water, air, and filter media to reduce PM and
GACT, heat input capacity, each) SO2 emissions in the boilers and also used
Subpart 6J conditionally for additional control of
noncondensibles depending on fuel fired in
the boilers for the poultry processing
equipment
ES-23 and Two natural gas-fired NA NA
ES-24 temporary,back-up boilers
(less than 90 MMBtu/hr max
heat input capacity, each)
ES-10A.1* One poultry by-product cooker CD-10E One venturi wet scrubber(voluntary for odor
and one dual-use control state-only requirement)
feather/poultry by-product
cooker(ID No. ES-10A.1),
or
ES-10A.2*, and One feather dryer and one CD-1 OD One two-stage crossflow wet scrubber(500
hydrolyzer(ID No. ES-10A.2), gallons per minute nominal liquid injection
and rate per stage) and a dry filter mist eliminator
or
ES-10E* Two liquid/fat evaporators CD-10F One packed bed scrubber(288 to 575 gallon
(ID No. ES-lOE) per minute normal operating range)utilizing
water, air, and filter media to reduce PM and
SO2 emissions in the boilers and also used
conditionally for additional control of
noncondensibles depending on fuel fired in
the boilers for the poultry processing
equipment
ES-lOB* Poultry by-product presses and CD-10D One two-stage cross flow wet scrubber(500
preheater(ID No. ES-1OB), gallons per minute nominal liquid injection
and rate per stage) and a dry filter mist eliminator
or
ES-101)* Process room air collection CD-10F One packed bed scrubber(288 to 575 gallon
(ID No. ES-IOD) per minute normal operating range)utilizing
water, air, and filter media to reduce PM and
SO2 emissions in the boilers and also used
conditionally for additional control of
noncondensibles depending on fuel fired in
the boilers for the poultry processing
equipment
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The following insignificant sources are listed in the permit attachment. There is one cooling tower that
may eventually need to be added to the list.
ID Number Equipment Description
IES 17 Poultry meal conveyance system
I-WCCS Wastewater collection and conveyance system
IES-11,IES-12,IES-13, Six(6)meal storage silos(ES-11 and ES-14 are 300
IES-14,IES-15, and IES-16 tons capacity and the rest are 100 tons capacity)
IES-19 Meal loadout area(54 tons per hour capacity)
It should be again noted that the cookers,feather dryer,feather hydrolyzer,presses,preheater,and
evaporators are actually controlled 24/7 by the venturi and packed bed scrubbers. Valley Proteins
does not take advantage of the conditional use made available by the permit source table above.
Only the room air vents exhaust to the crossflow scrubber.
Inspection Observations and Regulatory Review
I performed a physical inspection of the rendering plant and a permit records review on 9/03/2019. The
inspection was performed using the current Title V permit(T32). The inspection was completed with
assistance from Mr.Van Jones(Corporate Environmental Manager)and Mr. Brett Elliott(Plant Manager).
Mr. Johnny White also assisted with the physical inspection of the facility. Following our visit,Valley
Proteins provided requested raw material load processing records on 9/04/2019 by email. My review of these
records was not completed until 10/07/2019.
No issues were observed with the sources and control devices during the inspection. There were no holes
or tears observed in the ductwork or control devices.
The packed scrubber is filled with stainless media. Mr.Anderson previously noted that airflow to the
packed scrubber is approximately 86,000 ACFM.
The plant operates six days a week and on Sundays if there are overflow loads or backlogged loads. The
past weekend they had operated Sunday due to the Fayetteville facility shutting down due to a blown
transformer. Most of the meat and feathers are supplied by the Perdue processing facility next door,but
they do receive loads from other facilities each day. Sanderson Kinston is another large supplier. They
are now processing Butterball turkey rendering in cooker No. 2. Cooker No. 1 processes only chicken.
Cooker No.1 operates 24/7,but Cooker No.2 starts up in the very early hours of the morning, and has 3-4
hours of downtime at the end of each day. Feathers are processed approximately 20-21 hours each day.
Due to the three-day Labor Day holiday weekend,the facility was not in operation at the beginning of the
inspection,but was in startup during my physical inspection. During the physical inspection of the
sources and control devices, I observed the crossflow scrubber flowmeters reading at 500 gpm each(with
some fluctuation up to 525 gpm). The packed scrubber flowmeter read at 550 gpm. I observed the
packed scrubber flowmeter at 800 gpm,but it suddenly dropped to approximately 50 gpm,then zero.
Maintenance staff immediately investigated and found that the scrubber pump discharge valve had failed
while we stood there. It was repaired while I was there for the inspection.
Note that one of the evaporators has not been in use for the last couple of years. It serves as a holding
tank for the other evaporator. Valley Proteins installed a new plant-wide control system in early 2018.
The system does not fully automate feed; there are still a number of manual controls.
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Two natural gas/saleable animal fats/No. 6 fuel oil-fired boilers (ID Nos. ES-8 and ES-9)
with associated packed tower scrubber (ID No. CD-10F) and two natural gas-fired
temporary, back-up boilers (ID Nos. ES-23 and ES-24)
Regulated Limits/Standards Applicable Regulation
Pollutant
Particulate matter 0.27 pounds per million Btu heat input(ES-8 and ES-9) 15A NCAC 2D .0503
0.25 pounds per million Btu heat input(ES-23)
0.23 pounds per million Btu heat input(ES-24)
Sulfur dioxide 2.3 pounds per million Btu heat input 15A NCAC 2D .0516
Visible emissions 20 percent opacity 15A NCAC 2D .0521
TSP Less than 41 tons per year combined 15A NCAC 2Q .0317
PMI0 Less than 28 tons per year combined (PSD Avoidance)
Sulfur dioxide Less than 215 tons per year combined
VOCs Less than 40 tons per year combined
Carbon monoxide Less than 106 tons per year combined(as aggregate of
Nitrogen oxides all fuel combustion)
Less than 107 tons per year combined
Hazardous air National Emission Standards for Hazardous Air 15A NCAC 2D .I I I I
pollutants Pollutants for Area Sources—Industrial, Commercial, (40 CFR 63, Subpart JJJJJJ)
and Institutional Boilers
W.E. Partners supplies 70-80%of the steam demand at the rendering plant. W.E. Partners is not capable of
making enough steam to supply 100%if Valley is in full production. Valley Proteins usually operates one of
the boilers(they alternate)to supplement. On a continuous full operation day the steam demand can be as
much as 75,000-80,000 lbs/hr. When it is down,Valley Proteins can operate both of their boilers as needed.
The boilers were not in operation during my physical inspection. Boiler ES-8 had its tubes and wall replaced
during the summer of 2018. Boiler ES-9 had its tubes and wall replaced beginning November 2016.
A temporary boiler was brought on site for the ES-8 tube and wall replacement. They also used a
temporary boiler in February 2019 for a boiler repair(it combusted 26 mcf).
2D.0503 "Particulates from Fuel Burning Indirect Heat Exchangers"
Permit Conditions 2.LA.1. and 2.I.B.1.
The boilers have never been tested for particulate. There has been no gas curtailment since DAQ's last
inspection on 8/31/2018.
ES-8 and ES-9 each have an emission limit of 0.27 lb/MMBtu, and the temporary boilers have limits of 0.25
lb/MMBtu and 0.23 lb/MMBtu. Assuming worst case No. 6 fuel usage,boiler ES-8 and ES-9 uncontrolled
particulate emissions are estimated using an AP-42 factor:
88,400,000 Btu/hr(gallon/15 1,000 Btu)(24 lb/1000 gallons)= 14.05 lbs/hr emitted
14.05 lbs/hr(hr/88.4 MMBtu)=0.16 lb/MMBtu
The temporary boilers would operate on natural gas. The AP-42 emission factor for particulate from natural
gas combustion is 0.007 lb/MMBtu. There are no monitoring/recordkeeping/reporting(MRR) conditions for
2D.0503. Valley Proteins is in compliance with 2D.0503.
2D.0516 "Sulfur Dioxide Emissions from Combustion Sources"
Permit Conditions 2.1.A.2. and 2.I.B.2.
The regulation applies to the No. 6 fuel oil and natural gas combustion in the boilers. No animal fats have
ever been combusted at the facility. No monitoring is required for natural gas combustion. Permit Specific
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Condition 2.1.A.2.d. states that the sulfur content in the fuel oil must not exceed 2.1%by weight. Permit
condition 2.1.A.2.e. and g. require Valley Proteins to maintain sulfur certifications per shipment of fuel oil,
and to submit semi-annual fuel oil sulfur certification summary reports to DAQ. No fuel oil shipments have
been received since 2/20/2015, and that shipment was compliant. Valley Proteins has submitted complete
semi-annual reports on time. Valley Proteins is in compliance with 2D.0516.
2D.0521 "Control of Visible Emissions"
Permit Conditions 2.I.A.3. and 2.I.B.3.
Visible emissions from all of the boilers must not exceed 20 percent opacity when averaged over a six-
minute period. Six-minute averaging periods may exceed 20 percent not more than once in any hour and
not more than four times in any 24-hour period. There are no monitoring/recordkeeping/reporting
requirements for the temporary boilers.
When No. 6 fuel oil is combusted, emissions are vented to the packed scrubber,which creates a very
visibly wet plume. Therefore, alternative monitoring has been required to demonstrate compliance with
the visible emissions limit. Permit Condition 2.1.A.3.d.requires the following activities associated with
the packed tower scrubber:
• Emissions from the boilers must be controlled at all times by the packed bed scrubber when
combusting fuel oil(with exception of tune-ups).
• Perform semi-annual external inspection of the packed bed scrubber.
• Record the scrubber flow rate at least once per day and verify that the flow rate is within the
manufacturer's specifications.
• Perform weekly cleanouts of the scrubber and monthly instrumentation inspections.
• Scrubbing binder must be in use daily from March 1st through September 30t'each year.
• Binder must be added weekly.
The boilers are operated on gas, and fuel oil is only used in curtailment. No fuel oil was fired for curtailment
since the date of last inspection. I reviewed the fuel usage records back to August 2018. They used 1,576
gallons of oil on 12/16/2018 for boiler ES-8 tuning. No other oil usage was recorded. Their semi-annual
report lists 1,576 gallons per month for January through June 2019. This appears to be a mis-type.
Note that the above records were reviewed as part of compliance evaluation against Specific Condition
2.2.A.1. for 2D.0541.
Valley Proteins is in compliance with 2D.0521.
15A NCAC 02Q.0317.Avoidance Conditions for
2D.0524 "New Source Performance Standards"Subpart Dc
Permit Condition 2.1.B.4.
To avoid applicability of NSPS, any temporary boiler must meet the following requirements
• Meet the definition of a temporary boiler under NSPS 60.41 c.
• Ensure that the boiler rating doesn't exceed 90 MMBtu/hr.
• Only fire natural gas.
• Keep records demonstrating that the boiler(s) is not on-site for more than 180 consecutive days.
The temporary boiler used during summer of 2018 and the boiler brought in during the month of February
2019 meet the above requirements. Valley Proteins is in compliance with the permit condition.
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2Q.0317"Avoidance Conditions"for
2D.0530 "Prevention of Significant Deterioration"
Permit Condition 2.I.A.4.
In order to avoid applicability of 15A NCAC 21) .0530(g) for major sources and major modifications,
boilers ES-8 and ES-9 are limited to the following emissions per consecutive 12-month period:
Pollutant Actual 2-Year De minimus level PSD limit
Average (tpy) (tpy)
(t
PM 16.2 25 41
PM10 13.15 15 28
Sulfur dioxide 174.65 40 215
VOCs 0.37 40 40
Carbon monoxide 6.13 100 106
Nitrogen oxides 1 67.4 1 40 1 107
The packed tower scrubber is required to provide emissions control when the boilers are firing No. 6 fuel
oil. Since DAQ's last inspection date 1,576 gallons of fuel oil have been combusted on 12/16/2018 for
tune-up of ES-8.
Valley Proteins is required to calculate monthly sulfur dioxide emissions from all fuels. The facility is
also required to calculate monthly carbon monoxide emissions using AP-42 factors for the emissions
from fuel oil and natural gas combustion, and 0.0170 pounds per million Btu for the emissions from
saleable animal fat combustion. No fat has ever been combusted at this facility.
The facility is required to keep a record of the monthly emissions along with a record of the amount of
each fuel combusted. The records must also include verification that the packed tower scrubber operated
while No. 6 fuel oil was used. The records indicated that the vent was opened to the scrubber during the
12/16/2018 ES-8 tune-up.
Permit condition 2.1.AA.g. requires the facility to submit semi-annual summary reports containing the
following information:
• the monthly sulfur dioxide emissions for the previous 17 months. The emissions must be
calculated for each of the 12-month periods over the previous 17 months.
• the monthly quantities of natural gas, saleable animal fats,and fuel oil consumed for the previous
17 months.
• the average sulfur content of the fuel oil.
• the monthly carbon monoxide emissions from the previous 17 months. The emissions must be
calculated for each of the 12-month periods over the previous 17 months.
Valley Protein's gas totalizer is read on a daily basis, and the daily records are all recorded on a monthly
logsheet. Fuel oil use is also tracked,but it isn't exact due to liquid expansion. Mr. Van Jones uses fuel
totals provided by Corporate Accounting for the emissions inventory and reporting.
Total reported CY2018 gas usage was 133.83 MMCF. 1,947 gallons of No. 6 oil were combusted in the
boilers in CY2018. No fuel oil has been combusted so far this year. The rolling annual total S02
emission has been negligible. CO rolling annual emissions are less than 10 tons so far this year. The
reports have been submitted on time. The reports are complete and demonstrate compliance with the
permit condition. Valley Proteins appears to be in compliance with 2Q.0317.
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2D.1111 "Maximum Achievable Control Technology"
Subpart JJJJJJ-NESHAP for Boiler Area Sources
Permit Condition Z LA.5.
This facility is a minor source of HAPs. Perdue submitted the initial notification for the boilers on 9/20/2011.
They resubmitted the initial notification on 7/12/2013 (to account for changes to the regulation). Permit
Condition 2.1.A.5. is written with the assumption that the boilers use multiple fuels. However,these boilers
have been operating on natural gas with fuel oil only used for maintenance and curtailment. As long as
boilers ES-8 and ES-9 meet the definition of a natural gas boiler as provided in the regulation,there are no
requirements under Subpart 6J. However,Valley Proteins has completed tune-ups and energy assessments
for the boilers, so they can burn oil whenever they wish.
The facility is required to perform biennial tune-ups of the boilers. Each tune-up must include the
following:
• Inspection of the burner, and cleaning/replacement of any components of the burner as necessary.
• Inspection of the flame pattern, as applicable, and adjustment of the burner as necessary to optimize
the flame pattern. The adjustment should be consistent with the manufacturer's specifications, if
available.
• Inspection of the system controlling the air-to-fuel ratio, as applicable, and ensurance that it is
correctly calibrated and functioning properly.
• Optimization of total emissions of carbon monoxide. This optimization should be consistent with the
manufacturer's specifications, if available.
• Measurement of 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.
The facility performs tune-ups at least a couple of times a year,but not all include every requirement under
6J. Valley Proteins did complete tune-ups in 2017. ES-9 was tuned on gas fire on 9/19/2018. ES-8 was
tuned on oil on 12/16/2018. Natural gas-fired tune-ups that meet the requirements for both boilers were
completed on 6/26/2019. The tune-ups were conducted by Mid-South Steam Boiler Engineering Co,Inc.
Boiler maintenance is conducted according to weekly work orders,which I did generally review during the
inspection.
Valley Proteins submitted their Notice of Compliance Status on EPA's CDX-CEDRI database on 6/03/2014.
A hard copy of the CDX submittal is in the WARO file. The energy assessments were completed 10/20/2014,
with an update conducted on 5/27/2015. The energy assessment document is on file at the facility. Copies of
the cover page and table of contents are in the WaRO file.
Specific Condition 2.1.A.5.c.ii.C. requires documentation of the fuel used monthly by each boiler. Valley
Proteins is recording the fuel usage under permit Specific Condition 2.1.AAS. as well. Fuel consumption
records are complete.
A biennial compliance certification is required starting 3/1/2015. The compliance certification must
contain the information specified in paragraphs 40 CFR 63.11225(b)(1)through(4)and must be
submitted upon request. The report must only be submitted to DAQ by March 15 if the facility has any
deviation described by paragraph(b)(3) of 40 CFR 63.11225. Otherwise the report is to be kept on file at
the plant. Bob Vogler(Corporate Environmental) completes this report annually. The certifications are
on file at the facility. The most recent one is dated 1/08/2019.
Valley Proteins appears to be in compliance with 2D.1111 and NESHAP Subpart 6J.
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Six poultry meal storage silos (ID Nos. ES-11 through ES-16), one poultry meal loadout
area ID No. ES-19 , and poultry meal conveyance IES17)
Regulated Limits/Standards Applicable Regulation
Pollutant
Particulate Matter For process rates greater than 30 tons per hour: 15A NCAC 213 .0515
E=55.OxP°-1-40
Where: E=allowable emission rate in lbs/hr
P=process weight in tons/hr
Visible Emissions 20 percent opacity 15A NCAC 2D .0521
2D.0515 "Particulates from Miscellaneous Industrial Processes"
NO PERMIT CONDITION
These sources have been deemed insignificant, and are listed in the Insignificant Activities Attachment to the
permit. However,this rule still applies. See previous inspection reports for emissions estimations from the
silos and loadout. Emissions from meal conveyance are expected to be negligible. The meal is very moist
and the system is covered. The insignificant sources are in compliance with 2D.0515.
2D.0521 "Control of Visible Emissions"
NO PERMIT CONDITION
Visible emissions from the silos,meal loadout, and meal conveyance must not exceed 20 percent opacity
when averaged over a six-minute period. Six-minute averaging periods may exceed 20 percent not more
than once in any hour and not more than four times in any 24-hour period. The insignificant sources are
assumed in compliance with 2D.0521.
2.2 -Multiple Emission Source(s) Specific Limitations and Conditions
Facility Wide Affected Sources
2D.0535 "Excess Emissions Reporting and Malfunctions"
Permit General Condition 3.La. and 3.LB.
Valley Proteins is required to report excess emissions from deviations or malfunctions that last more than
four hours. Several malfunctions have been reported since the date of last inspection. NC DAQ Excess
Emissions Forms with associated malfunction determinations are saved to SharePoint and IBEAM
Documents.
• 8/23/2019 The crossflow scrubber fan was badly damaged. Metal fatigue was the cause. The
blades hit the housing and broke. A replacement was ordered. The repair wasn't completed until
8/27/2018. 2,200 lbs of VOC were estimated as emitted while the scrubber was down.
• 8/28/2019 The fan replacement failed,and the facility had to look for another fan. A temporary
fan was installed 9/03/2018.
• 10/04/2018 The temporary fan motor failed. A new fan was installed 10/07/2018. The estimated
emissions were 3,301 lbs of VOC.
• 11/21/2018 Several brief fan repairs to the crossflow scrubber were made taking less than 4
hours total. On 11/23/2018 the scrubber went down for 5.5 hours for fan work. Total emission
was 126.1 lbs VOC.
• 2/23/2019 The crossflow scrubber fan had a mechanical failure. It was down for six hours. 203
lbs of VOC was estimated as emitted.
The above incidents were determined to be malfunctions by the Regional Supervisor. Valley Proteins is
considered in compliance with 2D.0535.
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2D.0539 "Odor Control of Feed Ingredient Manufacturing Plants"
Permit Condition 2.2.A L
There are residences on the other side of the tree line to the north that would be immediately affected by both
Valley Proteins and Perdue odors. West Bertie Elementary School is located nearby on North Highway 308.
I performed odor surveillance along Highway 308 north and south of the facility and along Black Jack Road
before and after the inspection. The only odor I sensed was mild"cooked"odor on Highway 308 in front of
the Perdue plant(before and after). There was little wind,but it appeared to be coming from the
south/southwest. There was raw material and cooked odor onsite as we conducted the physical inspection of
the facility sources and controls.
On the evening of February 3,2019 at 7:25 PM I was riding alongside the Perdue Foods and Valley Proteins
on Griffins Road. When I passed alongside the anaerobic ponds located between the two facilities,I
smelled a very strong,pure sulfur odor. The wind direction was coming from the north/northwest(from the
plants toward Griffins Road). The property across from the facilities as we passed through is undeveloped.
When I returned past the same area again at 10:30 PM,I did not smell any odor. The wind direction
appeared to again be from the north/northwest.
I have never smelled this pure sulfur odor around the facilities. I called Van Jones with Valley Proteins and
Joey Baggett with Perdue. Van did not know of any material they handle or produce that would generate a
pure sulfur odor(I associate a cooked`animal feed' odor with the rendering plant). Joey said that he had
never smelled pure sulfur around the Perdue facility or the WWTS(I associate a rotted,rancid smell with
the WWTS aeration pond). Joey contacted Tim Mizelle about the odor,and Tim emailed me on March 6'
that he had never observed such an odor as well,but he will monitor for it going forward. I did not smell
this odor during my inspection on 9/03/2019.
Cooked odor is usually a musty, slightly bitter smell. On warm,humid,and/or windy days,I have historically
smelled it off-site. The cooked odor is coming from the scrubber stacks, so can be dispersed with wind
direction. Odor is also generated by the wastewater treatment system,which supports both Valley Proteins
and the Perdue chicken processing plant. However,the wastewater system is owned and operated by Perdue.
There are ponds with aerators located between the processing plant and rendering plant. The wastewater
treatment system odor appears to be stronger and more offensive than the cooked odor from the rendering
plant. Wastewater odors are more likely prevalent in the summer months when operating the aerators.
Perdue staff are supposed to pay attention to wind direction before running all of the aerators on really hot
days.
There should never be an issue with odor from having to dump blood tanks since they constructed
underground piping from the tank to the anapond. If they had to perform an emergency unloading of a tank or
if a tank overflowed,they would use a suck truck to remove the blood. If a tank were to run over,the blood is
fresh, and I was told it would produce low odor.
WaRO has not received a complaint call since the last inspection date. Mr. Elliott and Mr. Jones confirmed
that Valley Proteins has not received any odor complaints since then as well. Mr. Elliott is required by the
company to call DAQ if they get an odor complaint. He must also immediately personally investigate the
complaint by going to the location of the complaint to evaluate, even if the odor is reported to have occurred
on a previous day. He must review previous complaint records and inspect current operation of the plant to
help determine if there is anything that needs correction. The company has an odor evaluation form that
must be completed and passed up through corporate environmental offices.
When the state odor rule for rendering plants was promulgated,the facility wished to avoid having to comply
with the storage requirements for raw materials. To do so,they must make sure that all meat is processed in
less than 36 hours, all feathers are processed within 48 hours and all used cooking oil is unloaded within 96
hours(per rule change on 9/30/2015, Session Law 2015-264, Senate Bill 513,page 12). Otherwise,they must
store the material in properly enclosed and vented areas that have odor control. Valley Proteins has an
electronic card system that tracks how long raw material loads are stored before being dumped to processing.
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The weigh scale tags truck delivery and departure. The scale is calibrated semi-annually. They have a
limited number of trailers, so they have to dump loads quickly so the trailers can adequately serve the
customer. The computer program will change the color for a load record as it ages to alert operators that it
needs to be processed. It turns yellow at 18 hours and red at 24 hours. However the front office usually goes
in search of loads once they've crossed 9-16 hours in storage.
Time card data is reviewed weekly and separate hard copy reports are kept of loads that exceeded or appeared
to exceed 18 hours. It should be noted that if the electronic card records have a"7"denoted in the dump pit
column,it means that the load was shipped off-site rather than processed.
Necks and feet get processed slower because the bone must be mixed a little at a time with the other meat.
No raw material is usually allowed to just sit on the pad indefinitely. Poorly cooked material(called
"greasy meal")that is blended back into the raw material on the front end may sit on the pad,but is
usually reprocessed within 3 hours. Fully cooked rejected meal can also be reprocessed, and it will sit on
the pad for up to two days. There was some rejected(fully processed)meal sitting on the pad during the
inspection. I did not smell any odor from the meal. Wet feathers are no longer pushed onto the pad for a
short while to drain. They are drained out the bottom of the truck.
MDM(mechanically deboned material) is composed of bone hash that robs protein from the meal and
creates ash in the cookers. Valley Proteins has installed a bin for MDM to avoid putting it on the pad.
Most MDM is shipped off-site.
Normal loads approaching the hours limitation may be backed into the loading bays so that the room air
vacuum could pull air across the trailer into the crossflow scrubber. I talked to Robert Hayden with FRO
about this practice(they have a couple of Valley Protein facilities in the region) following my August 2014
inspection. NCDAQ has accepted this method of storage as acceptable under the rule. The facility tries to
avoid implementing this practice,but they do employ it when necessary.
Time card records for grease tanker trucks and blood tanks may be disregarded because those trucks unload to
closed systems not regulated under 2D.0539. Refrigerated trucks are also exempt from the 36-hr clock. They
usually contain bone backs,frames and thighs in totes. Trash truck time cards may be disregarded because
the trash is not rendering plant raw material, it is normal landfill solid waste. Sludge is a waste material that
comes out of the wastewater system. It has fat in it. It is pumped in an enclosed system to an enclosed truck
and sent off site for fat recovery. Timecards for sludge may be disregarded.
I reviewed the `over 18 hours' report for September 2018-August 2019 and did some comparison to the
2/19/2019 revised semi-annual report. The overdue load data reported to DAQ matched their records. Seven
loads were processed late in July due to high inventory volume coming from Rose Hill as a result of a major
fire at that plant. Fifteen loads during the period were processed late due to high inventory volume coming
from other plants that had major breakdowns. Three loads were processed late due to Hurricane Florence.
Two loads were processed late due to high inventory volume from Rose Hill while it prepped for weather
(Michael). The late loads due to the Rose Hill fire and the storms are excusable. Thirteen of the fifteen late
loads due to other facilities in midst of breakdowns are MDM. Mr. Elliott was not the manager at that time,
but he looked into why the loads were delayed, and believes they were held because the receiving facility was
not available and there were no options for transfer out. The two meat loads were delayed due to high
inventory volume while the repairs were made at the other facility. This is not a normal problem for load
delays, so no enforcement action is taken for the fifteen loads. There were no late loads for January 2019 to
the date of inspection.
Note when reviewing records,keep an eye out for loads associated with MDMs or rejected meat loads that
may have a process time recorded over 36 hrs,but have shipping tickets attached showing that the loads were
actually shipped off-site in under 36-hours. Shipping tickets from the receiving plant are attached to those
records,proving the time the loads actually left the Lewiston site. These loads should also have the `7' tag in
the dump pit column of the records.
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2D.0539 requires that their raw material trucks be tarped while in transport. Trailers containing raw
material sit near the receiving pad behind the office building. Empty trailers are stored in the open yard in
front of the plant. The rule does allow for uncovered raw material as long as it was generated on-site at
the Perdue processing plant. Once a trailer dumps into the receiving bay, it is washed with hot water.
This is a potential source of odor. Because the plant was preparing to start up, I only observed empty
trailers onsite during the inspection.
It is my understanding that as long as building pressure is negative,the loading bay doors to the rendering
plant do not have to be closed all of the time. It is corporate policy to keep the large scroll doors open
knee to belt level.
The rule requires Valley Proteins to send process gases through condensers to remove all steam and other
condensable materials. The rule requires control of expeller(press) gases. All noncondensible gases are to
be incinerated at 1,200 degrees Fahrenheit for a period of not less than 0.3 seconds, or treated in an
equally effective manner. DAQ has approved control of process gases with operation of a condenser,
venturi scrubber and packed scrubber. The presses are hooded and ducted to scrubber control. Room air
goes to the crossflow scrubber.
Permit conditions 2.2.A.1.c.ii. and iii. require Valley Proteins to use a scrubbing binder in the cross flow
and packed bed scrubbers(CD-1OD and CD-1OF)daily from March 1 through September 30 of each year,
and to add the binder weekly with each water flush. B-10 binder is a black liquid that smells like pine sol.
It is supposed to be a self-sustaining,regenerating biological. It enhances the ability of the water to trap
noncondensibles at higher temperatures. Only about 8 oz. is required per charge. Permit condition
2.2.A.Le.ii. requires the facility to keep a record of when the binder is added. I reviewed the records back
to September 2018, and they were complete. Valley Proteins is adding binder every week, all year.
Binder addition is noted in both the scrubbers' daily flow records and their weekly nozzle inspection
reports. Example records are attached to the file copy of this report.
The Valley Proteins Quality Assurance Plan is in the WaRO file. It has not been updated since 2016. The
plan mirrors permit requirements and references use of the O&M manuals for plant equipment to satisfy a
quality assurance program. In addition to the plan Valley Proteins conducts annual corporate environmental
audits.
Conditions 2.2.A.Lb. and c. contain monitoring requirements for the scrubbers:
• semi-annual inspection of crossflow scrubber spray nozzles and perform maintenance and repair
when necessary to assure proper operation of the scrubber,
• monthly inspection, cleaning, and calibration of all associated instrumentation,
• semi-annual external inspection of the venturi scrubber, crossflow scrubber and packed scrubber
for structural integrity,
• weekly cleanout of the packed bed scrubber; and
• install,operate, and maintain a liquid flowmeter on the crossflow scrubber. The liquid flow rate
into each stage of the scrubber shall be no less than 500 gallons per minute of water, or water and
additives. The flows must be recorded daily.
I reviewed records for all the above monitoring back to September 2018. The records were complete, and
monitoring has been satisfactorily conducted. They perform weekly external inspection and weekly
cleanouts on all three scrubbers,as well as weekly fan maintenance checks on all three scrubbers. The
crossflow scrubber spray nozzles are inspected weekly. An example weekly inspection record is attached
to the file copy of this report. All of the scrubber fans,pumps and ducts have weekly mechanical
maintenance and cleanouts. The packed scrubber is drained and washed weekly. The packed scrubber is
opened every couple of months to add a detergent cleaner.
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Flowmeters are inspected weekly. The flowmeters are sent out for re-calibration or replaced annually.
At least one new flowmeter is kept available on-site. The flowmeters are checked daily for mechanical
issues by operators as part of their daily maintenance route.
The daily crossflow scrubber flow measurements were complete and compliant. Air flow through the
crossflow scrubber is approximately 60,000 cfm. Flow on the packed bed scrubber is also recorded every
day. It's my understanding they try to maintain a minimum 400 gpm on the packed scrubber.
The facility must submit a semi-annual summary report for all monitoring requirements. The reports have
been on time and complete. Note that the January 2019 report incorrectly listed meat loads processed in
excess of 36 hours. All of the loads were actually MDM loads that were shipped off-site within 36 hours
or non-regulated loads. Valley Proteins appeared to be in compliance with 2D.0539.
2D.0540 "Particulates from Fugitive Non process Dust Emission Sources"
Permit General Condition 3.MM.
The facility may not generate fugitive dusts that go 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 dust fugitives from Valley Proteins come from truck traffic. I did not
see any fugitive dust leave the property boundary during the inspection.
2Q.0207"Annual Emission Inventory Requirements"(Condition 2.3.x)
The facility must submit an annual emissions inventory by June 30'each year. The accuracy of the report
must be certified by a responsible official of the facility. The CY2018 inventory was submitted
electronically on 5/30/2019. The certification was received on 6/06/2019. 1 reviewed and approved the
CY2018 inventory on 7/30/2019.
2Q.0508(n) "Compliance Certification"(Condition 2.3.P.)
The facility is required to submit an annual compliance certification to the DAQ and EPA Region 4 on or
before the first of March. The certification covers all federally-enforceable terms and conditions in the
permit,including emissions limitations, standards,or work practices for the previous calendar year. It must
be signed by a responsible official. DAQ received the 2018 ACC on 1/31/2019. 1 have reviewed and
approved the report.
Monitoring, Recordkeepin2 and Reporting (MRR)
All permit-required records were reviewed back to September 2018. The facility's reports have been
submitted on time. With exception of a minor issue with the January 2019 report concerning reporting of
loads that actually were not overdue,the reports are complete and compliant. The monitoring,recordkeeping
and reporting requirements in the permit are summarized below.
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Monitoring/Recordkeeping Requirement MRR Frequency Regulation Report Required?
Fuel oil certifications must be<2.1%sulfur Each shipment 2D.0516 Certifications
Packed scrubber operation while firing oil,scrubber As applied 2Q.0317 SA Deviation report
daily flow recorded
Nat gas/fuel oil/fat used in ES-8 and ES-9 Monthly 2Q.0317 for Monthly fuel amts
(PSD Avoidance)—No fat has ever been burned 2D.0530 and and 12-month rolling
2D.1111 totals SOz and CO
Subpart 6J bi-annual boiler tune-ups and compliance Bienniel 2D.1111 No
certification(only if they burn outside curtailment or
maintenance
Temporary Boiler days of operation<180 days Record at end of operation period 2D.0524 No
Rendering truck punch cards for load processing Per load(time of receipt and time of 2D.0539 SA Deviation report
unloadin
Crossflow scrubber I&M Semi-annual nozzle inspection 2D.0539 SA Deviation report
Venturi scrubber CD-IOE and packed scrubber CD-1OF Semi-annual external inspection 2D.0539 SA Deviation report
All scrubbers Monthly instrumentation inspection 2D.0539 SA Deviation Report
Add scrubbing binder weekly March 1'-September 301 Record dates of binder addition 2D.0539 SA Deviation report
Crossflow scrubber flow rates must be>500 m Daily 2D.0539 SA Deviation report
Maintenance logbook for all scrubbers Complete as work is conducted 2D.0539 SA Deviation report
Enforcement History
Valley Proteins has no enforcement history,but the following NOD's have been issued in the last five years:
0 8/25/2014-2D.0539(f), Specific Condition 2.2.A.1.
Eighteen raw material truck loads that were processed more than 24 hours after delivery.
• 2/06/2015-2D.0539(f), Specific Condition 2.2.A.1.
Five raw material truck loads on 7/10/2014,7/12/2014 and 8/13/2014 were processed more than 24
hours after delivery.
• 8/27/2015-2D.0521, Specific Condition 2.1.A.3.d.
Weekly visible emissions observation during fuel oil combustion on January 8,2015 and January 9,
2015 could not be provided during inspection.
0 9/12/2018-2D.0539(f), Specific Condition 2.2.A.1.
Three MDM truck loads and one skin load on 6/11/2018, 6/12/2018 (2 loads)and 6/18/2018 were
stored more than 36 hours after delivery.
Comments/Conclusions
The facility appeared to operate in compliance with the permit conditions and applicable regulations at
the time of the inspection.
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