AQ_F_0400034_20181029_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: 11/05/2018
Facility Data Permit Data
Valley Proteins,Inc. -Wadesboro Division Permit 06467/T18
656 Little Duncan Road Issued 10/3/2011
Wadesboro,NC 28170 Expires 9/30/2016
Lat: 35d 2.1192m Long: 80d 4.9683m Classification 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-Renewal
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP/Title V
James Hodges Matt Hanks Robert Vogler MACT Part Subpart 6J
Environmental Manager General Manager Director of NSPS: Subpart Dc
[phone] [phone] Environmental Affairs
[phone]
Compliance Data
Comments:
Inspection Date 10/29/2018
Inspector's Name Jeffrey D. Cole
Inspector's Signature: mil Operating Status Operating
Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: �����/8 On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
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
2015 2.33 0.3000 28.06 18.71 21.82 2.33 930.00
* 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

I. 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.
U. DIRECTIONS 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'/a 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.
M. 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—130 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 29 October 2018,I,Jeffrey Cole of DAQ FRO,arrived at Valley
Protein to conduct an air quality compliance inspection. I noted slight rendering odor prior to entering the
facility gate,and light odors while on site. I met with James Hodges, Environmental Manager. Mr.Hodges
reviewed the FacFinder data, and noted that Mr.Bivens,who was listed as authorized and facility contact was
no longer employed at the facility. Mr.Hodges updated those contacts and these changes have been made in
IBEAM.
I reviewed the plant's records which were very well-organized and are kept up-to-date. The plant combusts
natural gas exclusively unless curtailed or for testing, during which saleable fat is combusted. The facility
fired fat for testing for four days 30 October—2 November 2016, and again in January 2017, during a
curtailment. VE observations during these times indicate that there were no visible emissions. The plant has
not had its natural gas supply curtailed since the last inspection on 26 October 2017. The facility has not
accepted any fuel oil in years,and there was none on-site at the time of the inspection. 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 2018. After reviewing the facility's records,Mr. Hodges and I
toured the facility.
The facility was not 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—4 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. All three of these boilers were 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 consider 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 ENIISSION SOURCES:
Emrsawu Control lSource Emission Source Description Device Control Device Description
ID No. ID No.
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 1);both boilers were
not 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
One natural gas/No.2 fuel oil/No.6
fuel oil/On Specification recycled No.
B 5 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-I operating at I psig
consisting of.
E2,E3,E4-
a,E4-b,E4- C-2 venting to One cyclone(60-inch diameter)with a
c,E5-a,E5- either Mist eliminator in series with a
b,and E6 HAVE BEEN REMOVED CY-1 combination of three natural gas/fuel
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 Three natural gas/f tel oil/saleable fat
-fired boilers not operating as control
d)One feather press devices; C-4 operating at 6.5 psig
E10 Not operating C-3 One venturi scrubber(minimum
scrubber liquid inlet pressure 5 psig)in
C4 series with
One packed tower scrubber(minimum
scrubber liquid inlet pressure 3 psig)
C-3 operating at 9 psig; C-4 operating
- at 6.5 psig
C-6 One air cooled condenser
in series with
C-1 One venturi scrubber(minimum
scrubber liquid inlet pressure 9 psig)
El with a
Rendering process consisting of: Mist eliminator
One three stage slurry system C-I operating at 11 psig
evaporative condenser cooker with post
heater forced circulation chamber on 1" 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
Not operating CM-1 gas/fuel oil/saleable fat-fired boilers
B-1 to B-3 or One packed tower scrubber(minimum
C4 scrubber liquid inlet pressure 3 psig)
Three natural gas/fuel oil/saleable fat
-fired boilers not operating as control
E18 One fluidizer tank devices;C-4 operating at 6.5 psig
Not operating C-3 One venturi scrubber(minimum
scrubber liquid inlet pressure 5 psig)in
C4 series with
One packed tower scrubber(minimum
scrubber liquid inlet pressure 3 psig)
C-3 operating at 9 psig;C-4 operating
at 6.5 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
GI 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
Not operating CY-1 combination of three natural gas/fuel
CM-1 oil/saleable fat-fired boilers
B-1 to B-3 or One packed tower scrubber(minimum
C-4 scrubber liquid inlet pressure 3 psig)
Three natural gas/fuel oil/saleable fat
-fired boilers not operating as control
E8 Press/centrifuge process devices;C-4 operating at 6.5 psig
Not operating C-3 One venturi scrubber(minimum
scrubber liquid inlet pressure 5 psig)in
C4 series with One packed tower scrubber
(minimum scrubber liquid inlet
pressure 3 psig)
C-3 operating at 9 psig; C-4 operating
at 6.5 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 ACLXone—ZA300HS
C-8 operating at 28 psig(Stage 1)and
28 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/mmBtu
for boiler B-4, and 0.28 lb/mmBtu for boiler B-5.
APPEARED IN COMPLL4NCE—The facility has only combusted natural gas, and some
saleable fat in 2016. The AP-42 emission factor for natural gas is 0.0071b/mmBtu. Source
testing at the facility in April 2001 resulted in a PM emission factor of 0.05 lb/mmBtu 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 INCOMPLIANCE— The facility fires natural gas exclusively, and will combust
saleable animal fat during testing and curtailment; there is no fuel oil on-site. Some saleable fat
was combusted for testing in the period of 30 October—02 November 2016, and again in

January 2017 during curtailment, however they have combusted no saleable fat since the last
inspection (26 October 2017). The semiannual report was received on 11 July 2018, 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 in
low fire mode (pin position])with zero visible emissions during the inspection. There were no
visible emissions noted from the scrubber exhausts. The facility's 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 11 July 2018, and indicated compliance.
D. 15A NCAC 2D.0524 NSPS 40 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 INCOMPLIANCE—No fuel oil has been combusted since the last inspection. There is
no fuel oil currently on-site.
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 are complete, and emissions appear to
be calculated correctly using the emission factors listed in the permit. S02 emissions while firing
natural gas are inconsequential with the monthly emissions averaging—0.008 tons Aug 16
through Dec 17). CO emissions were consistently around two tons per month and the 12-month
rolling total equal to 19.9 tons from Aug 16 through Dec 17.
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 INCOMPLIANCE—The facility makes daily calculations of S02 emissions based
on fuel combusted the previous day. Sum content of fuels is so low that average daily S02
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(ID 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 1_61,where E
is the allowable emission rate in lb/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 COMPLLANCE—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 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, 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
9 psig. The packed tower scrubber C-4(3 psig minimum)was operating at 6.5 psig. The inlets to
crossflow scrubber C-8(13 psig minimum) were operating at 28 psig(1'stage) and 28 psig(2"d
stage). The ORP values were observed to be +683 in(packed tower scrubber C4)and+575 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 logfor checking high-fire status, when the boilers are usedfor 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—4 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.
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 INCOMPLIANCE—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 2D .0535, and report any permit deviations quarterly.
APPEARED EV COMPLIANCE— Mr. Hodges is aware that the permit requires reports of
excess emissions and of deviations, and submits reports if required. A notification was received
on I May 2018, indicating that,from 6:00-11:00 PM on 8 May 2018, a malfunction of chemical
feed lines occurred which led to ORP being low out of specification for cross flow scrubber
(CD ID No. C-8)for greater than four hours. Subsequent inspection discovered that there were
blockages in the rotameter and chemical feed lines which restricted the chemical flow to the
scrubber. The rotameter and the chemical feed lines were disassembled, cleaned out, and
reassembled and ORP was restored. The company stated that they were unaware of any excess
emissions during the event and had received no odor complaints. DAQ responded on
16 May 2018, stating that the plugging of the rotameter and the chemical feed lines, was
considered as a ma�Anction under 2D.0535(a)(2), and not a permit deviation.
The last quarterly deviation report was received on 11 October 2018, which showed two
instances of maffiinctions of the cross flow scrubber(CD ID No. C-8). The first was on 10 July
2018 when the ORP dropped below 300 mV for 49 minutes due to a hole in the chemical feed
line. 77ris feed line was replaced. The second instance was from 30-31 July 2018 when the ORP
dropped below 300 mV for 20 hours and 15 minutes due to a failure of an offsite power
transmission line. The facility called the power company and the line was repaired. The final
instance involved packed tower scrubber(CD ID No. C-4) lasting from 30-31 July 2018 when the
ORP dropped below 300 mV for 20 hours and 15 minutes due to a same power line issue that
affected C-8.
K. GENERAL CONDITION"P"—COMPLIANCE CERTIFICATION—The Permittee shall
submit a compliance certification annually no later than March 151
APPEARED IN COMPLIANCE—the facility's ACC was received on 10 January 2018, 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 30te.
APPEARED IN COMPLIANCE—The facility's CY2017 AQEI was received on 22 May 2018,
and appeared complete and accurate.

VIII. INSIGNIFICANT ACTIVITIES:
Emission Source I.D. Emission Source Description
IE-21.1, IE-21.2,and IE- One load-out operation consisting of two truck 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 REMOVED FROM SITE Chlorine dioxide generation and delivery system
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 IN COMPLIANCE with their air
quality permit on 29 October 2018.
PINK SHEET ADDITIONS:
- None.
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