AQ_F_1900065_20190807_CMPL_CAV-Rpt (4)

NORTH CAROLINA DIVISION OF Raleigh Regional Office
AIR QUALITY Bonlee Mills
NC Facility ID: 1900065
Inspection Report Date: 0812 1/20 1 9 County/FIPS: Chatham/037
Facility Data Permit Data
Bonlee Mills Permit:n/a
3732 Old Highway 421 North Issued: n/a
Siler City,NC 27344 Expires: n/a
Lat: 35d 39.0520m Long: 79d 25.0010m Class/Status: Registered
SIC: 2048/Prepared Feeds Nee Permit Status: Inactive
NAICS: 311119/Other Animal Food Manufacturing Current Permit Application(s):None
Program Applicability
Contact Data SIP
Facility Contact Authorized Contact Technical Contact
Jeff Sessoms Jerry Purvis, Sr. Jeff Sessoms
Feedmill Manager President Feedmill Manager
[phone] [phone] [phone]
Compliance Data
Comments: Facility appears to be in compliance operationally,however,it appears
to be in violation of record keeping. Failure to maintain records on-site to establish Inspection Date: 08/07/2019
facility-wide annual air pollutant emissions remain below the twenty-five(25)tons Inspector's Name: Jeff Bouchelle
per year threshold level. Operating Status: Operating
Compliance Code: Compliance-inspection
Inspector's Signature: Action Code: FCE
On-Site Inspection Result: Violation
Jeffrey L. Bouchelle
Date of Signature:August 21,2019
Total Actual emissions in TONSIYEAR:
TSP S02 NOX VOC CO PM10 *HAP
2015 26.23 --- 0.3100 0.0500 0.3500 11.53 ---
2010 ---
*Hi hest HAP Emitted(in pounds)
Five Year Violation History:
Date Letter Type Rule Violated Violation Resolution Date
05/10/2016 NOV 2D.0202 Registration of Air Pollution Sources 06/13/2016
05/10/2016 NOV 2Q.0304 Applications 06/13/2016
Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested

(I) DIRECTIONS TO SITE: From the Raleigh Regional Office (RRO), take I-440 (West)to US Highways 1 and
64,and take the exit for US Highway 64(West). Continue on US Highway 64(West)to Siler City and turn left onto
US Highway 421 (South). Continue approximately six (6) miles and turn right onto Elmer Moore Road. After
travelling approximately two (2)miles,turn right onto Old US Highway 421. The facility is approximately one-half
(%2)mile on the left.
(II) FACILITY DESCRIPTION: The facility is a manufacturer of swine and chicken feed pellets. Presently,the
feed mill employs eight(8)employees in the mill with three(3)employees in the office and five(5)truck drivers. The
mill operates Monday through Friday from 7:00 am to 7:00 pm;fifty-two(52)weeks per year. Corn and soy beans are
received on the rail line with meal, lime, and phosphate being received by truck. Product retention time within the
permit cooling operation is approximately six(6)minutes.
(III) SAFETY REQUIREMENTS: Personal protective equipment (PPE) includes, but is not limited to: a safety
hard hat, safety shoes, safety glasses,hearing protection,and a high visibility/reflective safety vest.
(IV) INSPECTION SUMMARY: On August 7, 2019, I (Jeff Bouchelle), conducted a compliance inspection on
Bonlee Mills in Siler City,North Carolina, (Facility ID: 1900065). After arriving at the facility,I met with Mr. Jeff
Sessoms,Feedmill Manager,of Bonlee Mills. First,we sat down and went over the records for the facility. Records
for the cyclones and bagfilters were complete and up to date. However, Air Emission Source Registration No.
1900065X00, No. 2 (15A NCAC 2D .0202), "records maintained on-site to establish that facility-wide annual air
pollutant emissions remain below 25 tons per year threshold level"are not being kept. I informed Mr. Sessoms this is
a violation of the registration for the facility. This same regulation was not being kept last year and the facility
received a Notice of Deficiency(NOD). This year,the facility will be receiving a Notice of Violation(NOV)for this
same regulation for not maintaining records. Next,Mr. Sessoms provided me with a walk-through of the feed mill.
All registered equipment was present and accounted for and seemed to be operating properly.
(V)REGISTERED EMISSION SOURCES:
Emission Source Control System
Description Description
rail and truck grain receiving pits NIA
feed grain hammermill bagfilter(s)
pellet cooling operation cyclone(s)
feed loadout N/A
Note: The feed grain hanunermill, pellet cooling operation, and feed loadout were observed in operation
during this inspection with no visible emissions observed by me. The rail grain receiving pit was not
observed in operation,but the truck grain receiving pit was observed in operation. All appeared fine with
the truck receiving pit. I observed approximately five percent (5%) opacity reading from the truck
receiving pit.
(VI)SPECIFIC REGISTRATION CONDITIONS:
Registration is issued in accordance with Application 1900065.17A received February 9, 2017, and is subject to the
following specified conditions and limitations:
1. Registration Criteria: Pursuant to 15A NCAC 2D .0202"Registration of Air Pollution Sources,"and 15A NCAC
2Q.0102(e),as requested by the Registrant,the facility-wide actual total aggregate emissions of particulate matter
(PM10), sulfur dioxide,nitrogen oxides, volatile organic compounds, carbon monoxide,hazardous air pollutants,
and toxic air pollutants shall be less than 25 tons per year. Registration shall not apply to any facility as follows:

a. Synthetic minor facilities that are subject to Rule 15A NCAC 2Q .0315;
b. Facilities with a source subject to maximum achievable control technology under 40 CFR Part 63;
c. Facilities with sources of volatile organic compounds or nitrogen oxides that are located in a nonattainment
area; or
d. Facilities with a source subject to NSPS,unless the source is exempted under 15A NCAC 2Q .0102 (g) or
(h)•
Appears to be in compliance.
a.Facility is not a synthetic minor subject to 15A NCAC 2Q .0315.
b. Facility is not subject to a MACT under 40 CFR Part 63.
c.Facility is not located in a nonattainment area emitting VOC's and/or oxides of nitrogen.
d.Facility is not subject to NSPS.
2. Record Keeping: (15A NCAC 2D .0202) -The Registrant shall maintain records on-site to establish that
facility-wide annual air pollutant emissions remain below the 25 tons per year threshold level. Records (in written
or electronic format) shall be maintained for a minimum of two years and made available to DAQ personnel upon
request.
Appears to be in violation. No records are being kept on-site which are readily made available to the inspector for
this requirement. Notice of Violation (NOV) is being sent to facility for this violation of their registration
requirement.
3. Notification Requirements: (15A NCAC 2D .0202) -The Registrant shall notify DAQ as soon as possible of the
following occurrences:
a. Process Modifications: modification of the processes from that listed in the"Emissions Equipment Table."
b. Name/Ownership/Location Change:upon changing the facility name,ownership or location from that as listed
in this Registration.
c. Emissions Increase: if facility emissions increase such that the 25 ton per year emission threshold would be
expected to be exceeded. The Registrant shall notify DAQ prior to exceeding this emissions threshold.
Appears to be in compliance. According to Mr. Sessoms, no process modifications have been made. No
name%wnership/location changes have been made. No emissions increases have been planned.
4. Liability:An Air Emission Sources Registration shall not alter or affect the power of the Commission,Secretary of the
Department,or Governor under NCGS 143-215.3(a) (12)or the liability of an owner or operator of a facility for any
violation of the applicable requirements.
Appears to be in compliance. Mr. Sessoms was made aware of this liability requirement. No such occurrences.
5. Department of Environmental Quality Inspections: (NCGS 143-215.3(a)(2)) -No Registrant shall refuse entry or
access to any authorized representative of the DEQ who requests entry or access for purposes of inspection, and
who presents appropriate credentials,nor shall any person obstruct,hamper, or interfere with any such
representative while in the process of carrying out his official duties.Refusal of entry or access may constitute
grounds for Registration revocation and assessment of civil penalties.
Appears to be in compliance. I was allowed onto the property for an adequate inspection review.

6. Environmental Management Commission(EMC)Regulations: The Registrant shall comply with applicable EMC
Regulations,including Title 15A NCAC, Subchapters 2D and 2Q. Details of these requirements can be found at the
following websites:
http•//deq nc fzov/about/divisions/air-qualit/quality-rules/rules#2D and
http://deq.nc.j4ov/about/divisions/air-quality/air-quality-i-ales/rules#2Q
A brief summary of the regulations known to apply to this facility at the time this registration was issued are listed
below(Note: this list may not include all applicable regulations).
Appears to be in compliance. Mr. Sessoms was made aware of the regulations and references.
7. Particulates from Miscellaneous Industrial Processes: (15A NCAC 2D .0515)-the allowable particulate
emission rate,"E,"in pounds per hour from any stack,vent, or outlet,resulting from industrial processes
shall not exceed the level calculated with the equation E=4.1(P)0.67 for a process rate,P,less than or equal to
30 tons per hour,or E=55.0(P)0-11-40 when Pis greater than 30 tons per hour. "P"equals the process rate in
tons per hour and includes the weight of all materials introduced into any specific process that may cause
any emission of particulate matter.
Appears to be in compliance. Demonstrated through Registration review process.
8. Control of Visible Emissions: (15A NCAC 2D .0521)-visible emissions from the emission sources shall not be
more than 20 percent opacity(manufactured after July 1, 1971)or 40 percent opacity(manufactured before July 1,
1971).
Appears to be in compliance. Emissions were observed to be approximatelyfive percent(S%)at the highest, which
was at the truck receiving pit.
9. Excess Emissions Notification Requirements: (15A NCAC 2D.0535)-the Registrant must report excess emissions
of any regulated pollutant lasting more than four(4)hours,and that result from a malfunction,to the Division of Air
Quality by 9:00 am of the next working day.
Appears to be in compliance. Mr. Sessoms stated no such excess emissions have occurred.
10. Fugitive Dust Control Requirement: (15A NCAC 2D .0540) -the Registrant shall not cause or allow fugitive dust
emissions to cause or contribute to substantive complaints or excess visible emissions beyond the property
boundary.
Appears to be in compliance. Mr. Sessoms was reminded to have drivers remain slow(5-10 mph) on the gravel
roadway. The facility is posted with a 10 mph speed limit sign.
11. Control Device Requirements: (15A NCAC 2D .0611)—the Registrant must inspect each control device
(bagfilter,fabric filter,cyclone, scrubber,condenser, etc.)per the manufacturer's recommendations,and at
a minimum annually,and maintain a logbook(either written or electronic) on-site of all inspections and
maintenance performed on the air pollution control equipment.
Appears to be in compliance. Records for maintenance and inspections of the bagl'llters and cyclones were
observed and found to be adequate.

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12. Control and Prohibition of Odorous Emissions: (15A NCAC 2D.1806)-the Registrant shall take suitable measures
to prevent odorous emissions from the facility operations from contributing to objectionable odors beyond the
property boundary.
Appears to be in compliance. No odors were detected beyond the facility property boundary.
(VII)COMPLIANCE HISTORY:
On October 31,2018,the facility was issued a Notice of Deficiency(NOD)for failure to maintain records on-site to establish
that facility-wide annual air pollutant emissions remain below 25 tons per year threshold level.
On May 10, 2016, the facility was issued a Notice of Violation(NOV) for being delinquent in the submittal of their
permit renewal application and 2015 emissions inventory, in violation of 15A NCAC 2D .0202 and Specific
Condition A.2 of Air Quality Permit 10181R00.
On June 10,2011,the facility was issued a Notice of Violation(NOV)for failing to obtain a permit modification prior
to an ownership change, in violation of NCGS 143-215.108 and General Condition B.8 of Air Quality Permit
02556R13. The facility obtained the current permit on July 19,2011,and no enforcement actions were taken.
(VIM CONCLUSIONS / RECOMMENDATIONS: The facility is currently in violation of Registration
Condition 2. of their Air Emission Sources Registration No. 1900065X00, by not keeping records for "records
maintained on-site to establish that facility-wide annual air pollutant emissions remain below 25 tons per year
threshold level." However, based on other observations during the walk-through inspection and other record
reviews, the facility appears to be in compliance with all other emission and procedural requirements contained in
their registration. This is the second year in a row the Registration Condition 2 requirement has been delinquent. I
recommend a Notice of Violation (NOV) for failure to keep records indicating facility-wide annual air pollutant
emissions remain below 25 tons per year. I recommend another inspection in one(1)year. ---JLB

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