S TATE OF M ICHIGAN

DEPARTMENT OF ENVIRONMENT, GREAT LAKES, AND ENERGY

AIR QUALITY DIVISION
EVALUATION TYPE: On-Site Inspection

FACILITY: Veos USA, Inc. (E8117) SRN / ID: E8117

LOCATION: 1336 E MAUMEE ST DISTRICT: Jackson

CITY: ADRIAN COUNTY: Lenawee
CONTACT: Dan Hofbauer EVALUATION END DATE:
STAFF: Stephanie Weems COMPLIANCE STATUS: Compliance

Facility Contact

Dan Hofbauer – General manager

Daniel-Hofbauer@veos-usa.com

Purpose

On December 12, 2024 I conducted an announced compliance inspection of VEOS US, LLC located in
Adrian, Michigan in Lenawee County. I was accompanied by Scott Miller, AQD Jackson District
Supervisor. The purpose of the inspection was to determine the facility's compliance status with the
applicable federal and state air pollution regulations, particularly Michigan Act 451, Part 55, Air Pollution
Control Act and administrative rules and Permit to Install (PTI) 38-06A. Additionally, AQD staff scheduled
this inspection in order to meet with the facility regarding the company ownership change and their
planned next steps.

Facility Background

Historically, this facility was owned and operated by Dairy Farmers of America to produce powdered
milk. In 2021, the facility was purchased by Crimson Holdings, and production switched to making
powdered eggs for the pet food industry. Not long after, AQD began receiving numerous odor
complaints, which led to escalated enforcement actions being taken against the company for violation
of Rule 901(b).

In 2023, AQD and Crimson Holdings entered into a Consent Order regarding the proper management of
the odors. Part of that Consent Order required Crimson Holdings to obtain a new PTI that included a
Nuisance Minimization Plan for Odors (NMPO) and for the company to install a scrubber system to help
control odors. The scrubber has since been installed, and PTI 38-06A was issued.

In October of 2023, AQD was given notice that VEOS USA had purchased the Crimson Holdings facility
through a bankruptcy court proceeding. Due to the nature of bankruptcy laws, the Consent Order that
was issued to Crimson Holdings does not transfer to VEOS and is effectively closed. The PTI, however,
dos transfer to the new company and VEOS has submitted a written statement that they accept and will
abide by the terms of the PTI.

Odor Observation and Facility Arrival

Before meeting with the facility contacts, I decided to conduct a brief odor observation in the area.

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 S TATE OF M ICHIGAN
DEPARTMENT OF ENVIRONMENT, GREAT LAKES, AND ENERGY
AIR QUALITY DIVISION
EVALUATION TYPE: On-Site Inspection
I arrived in the area of VEOS around 9AM. It was 15 degrees F, windy, with winds out of the west at
18mph and gust around 31 mph.

I began by approaching the facility on East Maumee. I noted a slight Level 1-2 odor on E. Maumee next
to the factory’s shipping and receiving area, but it didn’t travel far. I then turned left on Gulf and right on
Michigan. I stopped and sat here for a few minutes, but no odors were detected. I then turned right on
Dean, right on Church, left on Maumee, and left on Gulf. I stopped again, but no odors were detected. I
then turned around, turned right on Maumee, right on Church, right on Dean, left on Michigan, and left
on Gulf. At no time during this drive did I note any odors in the neighborhood.

Pre-Inspection Meeting

After conducting the odor observation, I met with Scott Miller and we entered the facility around
9:30AM. Upon entering, we called Dan who met with us and escorted us to a conference room to have
the pre-inspection meeting. Here, we also met with Remi, who is currently stationed at the plant from
Europe, in order to help them learn how VEOS operates.

During this meeting, Scott provided Remi with a brief history of AQD’s dealings with the facility, and he
explained that we will continue to investigate odor complaints and work with the company to resolve
odor issues. Remi indicated that he appreciated that. Remi then provided us a background of VEOS. He
explained that VEOS is a family-owned company that started about 50 years ago in Belgium and they
have since expanded to other European countries. They specialize in powdered protein – mainly blood
and eggs.

We then discussed how the facility has been operating. Dan indicated that the facility has not stopped
operations at all during the sale of the plant. He explained that the scrubber has been working well.
Though they worked with Tri-mer initially for tuning the device, they now maintain it in-house. Dan
explained that the chemicals used in the scrubber are the same ones that they can use for their
wastewater treatment. Scott asked if the facility had ever considered testing the scrubber for
performance. Dan and Remi said no. Scott indicated that it may be beneficial in knowing how well the
scrubber is working to remove certain pollutants.

Next, we asked what the company plans to do to help combat any remaining odors. Dan and Remi
explained that they want to do some tests to redirect the ventilation of the building to the scrubber.
They indicated that they plan to start doing this next month. They explained that they want to better the
air inside the facility, but they will need to modify the dryer ductwork. They said that they had met with
the dryer manufacturer last week about this. We then asked about any changes to production. Dan and
Remi indicated that there are currently no plans to change anything in the process.

Overall, Dan and Remi explained that the current objective for the company is to increase volume.
Currently the receive about 600,000 lbs per week of incoming raw material. About half of this incoming
material is shelled eggs, and the shells are removed from the facility about twice a week. The dryer
currently operates about 2-2.5 days per week. Dan explained that this week the dryer had operated
Tuesday evening until it was taken down this morning, and it would be starting up again today until
tomorrow morning. Dan explained that they are looking at how to reduce the dryer run time.

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 S TATE OF M ICHIGAN
DEPARTMENT OF ENVIRONMENT, GREAT LAKES, AND ENERGY
AIR QUALITY DIVISION
EVALUATION TYPE: On-Site Inspection
Additionally, the facility has routed some of the minor external emissions inside, like the wastewater
treatment process and the sludge tank emissions.

Inspection

After the pre-inspection meeting, we began the onsite inspection. We started by putting on boot covers
and white coats and washing our hands. We then entered the facility floor and observed the loading
bay. Dan explained that they get about 3-4 tankers per week. He explained that they always shut the
door when the tankers are inside, they rinse the bay after each tanker, and they clean the bay every
night. He stated that all internal drains go to the wastewater treatment.

Next, we observed the reverse osmosis system and the egg holding tanks. Dan explained that, once the
raw material is received from the tanker, it is held in product silos. From there it goes through the
reverse osmosis system, into the egg holding tanks, and then to the dryer.

We then proceeded to the dryer area. On the way, we stopped to observe the shell press. Dan explained
how they have a shell conveyor to move the shells to a dumpster in the bay. Removal of this dumpster
happens about twice a week, and it takes about 15 minutes. The old dumpster is removed and a new,
empty one is put in its place. The dumpster is taken to Wixom, MI.

After observing the shell removal, we then saw the pasteurizer area and the dryer. The dryer was
running at the time of the inspection.

We then viewed the packaging and warehouse area before heading to the wastewater treatment room
to observe the DAF system. Dan explained that the DAF handles about 40,000 gallons of wastewater per
day. The wastewater goes through the sump to Tank 1, then to Tank 15, to Tank 2, and then to the DAF.
When asked about the sludge, he stated that it is hauled away twice a week and the sludge tank is now
vented inside the building. We then went to the basement to observe how the wastewater treatment
area is vented internally. Dan explained that there is air intake from the wall of the DAF room that pulls
through the interior wall to the basement, up to a vent through the roof.

Post-Inspection Meeting
After leaving the facility floor, Scott asked Dan about the facility’s discharge and stormwater. We
discussed that the facility had just met with EGLE’s stormwater staff and are working on the facility’s no-
exposure permit. Dan explained that the facility had removed piping to the storm sewer in 2022.

We thanked Dan and Remi for their time and cooperation, and we departed the facility at approximately
11:30AM.

Record Review

While onsite I was able to review the facility’s records that are required for the dust collector and the
scrubber. The facility is keeping the required records for the pressure drop on the dust collector, and
these records show that the pressure stays around 3.13 inches WC, meeting the permit requirement of
below 4 inches. The facility also keeps records of the scrubber acid pH, the base pH, and the liquid flow
rate. These records appear to show compliance.

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 S TATE OF M ICHIGAN
DEPARTMENT OF ENVIRONMENT, GREAT LAKES, AND ENERGY
AIR QUALITY DIVISION
EVALUATION TYPE: On-Site Inspection

Compliance Summary
Based upon the facility inspection, review of the records, and review of the applicable requirements, it
appears that Crimson Holdings is in compliance at the time of this inspection.

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