AQ_F_0400043_20180412_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY Triangle Brick Co-Wadesboro
NC Facility ID 0400043
Inspection Report County/FIPS:Anson/007
Date: 04/17/2018
Facility Data Permit Data
Triangle Brick Co-Wadesboro Permit 08179/T10
- US Hwy 52 Issued 12/29/2017
Wadesboro,NC 28170 Expires 8/31/2018
Lat: 35d 1.1463m Long: 80d 5.1235m Classification Title V
SIC: 3251 /Brick and Structural Clay Tile Permit Status Active
NAICS: 327121 /Brick and Structural Clay Tile Manufacturing Current Permit Application(s)TV-Renewal
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP/Title V
Nathan Wallace Howard Brown,Jr. Howard Brown,Jr. MACT Part 63: Subpart JJJJJ
Plant Manager President and CEO President and CEO NSPS: Subpart 000, Subpart UUU
[phone] [phone] (9 19)544-1796
Compliance Data
Comments:
Inspection Date 04/12/2018
Inspector's Name Mitch Revels
Inspector's Signature: % Operating Status Operating
Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: / ^ Q/ On-Site Inspection Result Compliance
,[.
Total Actual emissions in TONS/YEAR:
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TSP S02 NOX VOC CO PM10 *HAP
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2016 13.19 22.02 9.26 4.58 42.38 10.99 9503.74
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2015 13.09 22.49 9.43 4.54 42.01 10.90 13802.45
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20714 13.33 22.31 9.37 4.61 42.81 11.11 14082.36
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*Highest HAP Emitted inpounds)
Five Year Violation History:None
Date Letter Tyye Rule Violated Violation Resolution Date
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Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested
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1. DIRECTIONS TO SITE: Triangle Brick is located on US 52 in Wadesboro,NC, Anson County. From
FRO, take US 401 south to US 74; turn right onto US 74 West. Follow US 74 thru Wadesboro. On the west
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side of Wadesboro,turn right,following US 52 north. Go approximately 3.5 miles and turn right into the first
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facility entrance;the office is on the left. Check opacities prior to entering(kiln stacks, openings in bldg.with
grinders).
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2. SAFETY:
Safety glasses and shoes required; hard hat and ear protection optional. An operating kiln is hot to touch;
exiting bricks and cars are hot. Keep hands out of brick-making mechanisms, grinders and extruders.
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3. FACILITY DESCRIPTION:
Triangle Brick Co. - Wadesboro is the second largest brick plant in the country. They make a variety of
bricks from clay and shale mined onsite. The material they mine is a consistent mixture of clay and shale.
As the material is mined, it is trucked up the hill to the facility where it is fed through a sizing grate. The
smaller material passes via conveyors to the storage shelter and the oversized material goes through a jaw
crusher to reduce the size and then continues to the storage shelter. There are two plants on site and the
material from the storage shed feeds both. From the storage shelter material is scooped into a feeder,run
through a scalper(oversized material goes to hammer mill)then material(the consistency of cornmeal)is
conveyed to storage silos. From the storage silos, the material is sent through two pug mills in series
where it is combined with water and mixed to an even consistency then fed through a machine that
extrudes the brick in a slab. The slabs are treated with a decorative coating (carrying agent is a -
sawdust/loam mixture), cut into individual bricks and then loaded on a `car' for transport through the
dryer and kilns. Hydrogen Fluoride from the kilns is controlled by a dry lime adsorber (DLA) installed
on each kiln. The firing takes more than two days. After firing the bricks are packaged into skid loads
(by a very cool robot)and stored prior to purchase and shipment.
4. INSPECTION SUMMARY.
On 12 April 2018, I;'Mitchell Revels, FRO DAQ, met with Mr. Nathan Wallace,the Plant Manager, Mr.
Ricky Merritt, Director of Manufacturing and Mr. Tommy Meggs, Kiln Supervisor to conduct the annual
compliance inspection. Triangle is currently operating Kiln #1 (K-1) and Kiln #2 (K-2) at approx. 10
tons/hr. each. The facility started operating the dry lime adsorber (DLA) on K-2 in August 2016 in
advance of their compliance date (September 4, 2016) for the case-by-case MACT for brick
manufacturing. They started Kiln#1 on 6 February 2017 with the associated DLA. The facility operates
the DLAs on the kilns in order to obtain a Title III (Hazardous Air Pollutants) synthetic minor (area
source) classification, thus avoiding the case-by-case MACT for brick manufacturing and the recently r
promulgated NESHAP 5J(Brick MALT). The most recent AQ permit, TV Permit No. 8179T10, issued
on December 29, 2017, removed the case-by-case MACT status and language now that DLAs are
operating on each plant. `
Facility records appeared complete and in accordance with their current permit requirements. We
discussed the DLA operation and factors like feeder rate settings and the interface they use (PLC)to see
the status and setting for the device. There is a limestone low level indicator near the base of the hopper
and an alarm is set to activate (visual and audible) when/if the hopper level gets below the low-level
indicator. Mr. Wallace stated that they routinely refill the hopper every 4-6 weeks, well before the level
reaches the low-level indicator. A screw is installed on the DLAs to feed the limestone from the cascades
(area where the limestone is reacted with the exhaust stream)to the peeling drum where the outer layer of
limestone is "peeled off." The peeling (dust) is dropped to a collection container and the unreacted
limestone is blown back up to the hopper to pass through the cascades again. The feeder settings are:
peeling drum on 30 min, off 30 min; screw is on 2 min, off 2 min while peeling drum is on.
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Both plants were operating during the inspections and during our tour around the facility I did not observe
any VE leaving any building nor any coming from the covered conveyor belt over to the pug mills.
5. EMISSION SOURCES:
{
{ PERMITTED SOURCES j g
Two Brick Tunnel Kilns
K-1 One natural gas/No.2 fuel oil/No.6 fuel CD-K1 Dry Limestone
Op on NG w/DLA;0% VE oil-fired Brick Tunnel Kiln(29.0 tons per Adsorber(DLA)
Op-40%full capacity hour material output rate,42.8 million Btu
per hour heat input rate
K-2 One natural gas/No.2 fuel oil/No.6 fuel CD-K2 Dry Limestone
Op on NG w/DLA;0% VE oil-fired Brick Tunnel Kiln(29.0 tons per Adsorber(DLA)
Op—45%full capacity hour material output rate,42.8 million Btu
per hour heat input rate
Rotary Coatings Dryer
SD-1 One natural gas-fired Rotary Coatings Dryer N/A N/A
NSPS UUU (8.1 tons of clay per hour material input rate,
Not Operating 0.3 million Btu per hour heat input rate
Primary Crushing Plant and Associated Conveyances
PC-1 and PC-2 Two shale feeders N/A N/A
1 Not op/2 Not installed
PC-3 and PC-4 Two scalp screens N/A N/A
j, NSPS 000
3 Not Op/4 Not installed
PC-5 and PC-6 Two jaw crushers N/A N/A
NSPS 000
5 Not op/6 Not installed
PC-7 One conveyor under PC-3 and PC-5 N/A N/A
NSPS 000
Not Operating
PC-8 One conveyor under PC-4 and PC-6 N/A N/A
E NSPS 000
Not installed
PC-9 One cross-over conveyor N/A N/A
NSPS 000
Not installed
PC-10 One shuttle conveyor N/A N/A
NSPS 000
Operating w/0% VE

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Two Secondary Clay Grinding Plants and Associated Conveyances
CG1 One clay feeder N/A N/A
Operating;0% VE
CG 2 One conveyor belt to scalping screen N/A N/A
NSPS 000
Operating, 0% VE
CG-3 One scalping screen N/A N/A
NSPS 000
Operating, 0% VE j
CG-4 One return conveyor belt for oversize from N/A N/A
NSPS 000 screens
Operating;0% VE
CG-5 One conveyor belt to hammer mill N/A N/A
NSPS 000
Operating, 0% VE
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CG-6 One hammer mill N/A N/A
NSPS 000
Operating;0% VE
CG-7 One conveyor belt under hammer mill N/A N/A
NSPS 000
Operating;0% VE
CG-8 One conveyor belt to finish screens N/A N/A
NSPS 000
Operating;0% VE
CG-10 through CG-13 Four finish screens N/A N/A
NSPS 000
Operating;0% VE
CG-14 One fines conveyor belt under screens N/A N/A
NSPS 000
Operating, 0% VE
CG-15 One conveyor belt to storage bins N/A N/A
NSPS 000
Operating, 0% VE
CG-16 One conveyor belt over storage bins N/A N/A t
NSPS 000
Operating, 0% VE
CG-17 through CG-21 Five storage bins N/A N/A
NSPS 000
Operating;0% VE
CG-22 through CG-26 Five feeders under storage bins N/A N/A
NSPS 000
Operating, 0% VE
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CG-27 One conveyor in front of storage bins N/A N/A
NSPS 000
Operating, 0% VE
CG-28 One conveyor to pug mill N/A N/A
NSPS 000
Operating, 0% VE
CG-29 One clay feeder N/A N/A
Operating;0% VE
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CG-30 One conveyor belt to scalping screen N/A N/A
NSPS 000
Operating, 0% VE
CG-31 One scalping screen N/A N/A
NSPS 000
Operating, 0% VE
CG-32 One return conveyor belt for oversize from N/A N/A
NSPS 000 screen
Operating;0% VE
CG-33 One conveyor belt to hammer mill N/A N/A
NSPS 000
Operating, 0% VE
CG-34 One hammer mill N/A N/A
NSPS 000
Operating;0% VE
CG-35 One conveyor belt under hammer mill N/A N/A
NSPS 000
Operating, 0% VE
CG-36 One conveyor belt to finish screens N/A N/A
NSPS 000
Operating;0% VE
CG-37 through CG-40 Four finish screens N/A N/A
NSPS 000
Operating;0% VE
CG-41 One fines conveyor belt under screens N/A N/A
NSPS 000
Operating, 0% VE
(, CG-42 One conveyor belt to storage bins N/A N/A
k NSPS 000
t Operating;0% VE
CG-43 One conveyor belt over storage bins N/A N/A
NSPS 000
Operating, 0% VE
if CG-44 through CG-48 Five storage bins N/A N/A
NSPS 000
Operating;0% VE
CG-49 through CG-53 Five feeders under storage bins N/A N/A
NSPS 000
Operating, 0% VE
CG-54 One conveyor in front of storage bins N/A N/A
NSPS 000
r Operating;0% VE
CG-55 One conveyor to pug mill N/A N/A
NSPS 000
Operating, 0% VE
Loam/ Sawdust Preparation Operation and Associated Conveyances
LS-1 Loam/sawdust feeder N/A N/A
Operating, 0% VE
i LS-2 One conveyor from loam/sawdust feeder to N/A N/A
I NSPS 000 finish screens
Operating;0% VE
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LS-3 One loam screen N/A N/A
NSPS 000
Not Operating
LS-4 One loam crusher N/A N/A
NSPS 000
Not Operating
LS-5 One oversize return conveyor from LS-3 N/A N/A i
NSPS 000
Not Operating
LS-6 One oversize return chute N/A N/A
NSPS 000
Not Operating
LS-7 One fines conveyor belt under LS-3 to N/A N/A
NSPS 000 bunker belt conveyor
Not Operating
LS-8 One belt conveyor to bunker N/A N/A
NSPS 000
Operating;0% VE
LS-9 One storage bunker N/A N/A
NSPS 000
Operating;0% VE 1
LS-10 One sawdust screen N/A N/A
NSPS 000
Operating;0% VE
LS-11 One conveyor to storage bins N/A N/A
NSPS 000
O era tin ;0% VE
LS-12 One oversize conveyor from sawdust screen N/A N/A
NSPS 000 '
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Operating;0% VE
Above Ground Storage Tanks
T-1 One 24,000 gallon above ground No. 6 fuel N/A N/A
NSPS Kb oil storage tank
T-2 and T-3 Two 24,000 gallon above ground No.2 fuel N/A N/A r_
NSPS Kb oil storage tanks
T-4 One 24,000 gallon above ground highway N/A N/A
NSPS Kb diesel fuel oil storage tank
T-5 One 24,000 gallon above ground Additive N/A N/A
NSPS Kb "A"storage tank
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PERMIT EXEMPT EMISSION SOURCES:
NNW
IS-Tank 3,000 gallon above ground gasoline storage tank
Not installed,Mr.
Merritt stated will
never be installed.

6. APPLICABLE AIR QUALITY REGULATIONS:
A. 15A NCAC 2D .0515 PARTICULATES FROM MISCELLANEOUS INDUSTRIAL
PROCESSES—Particulate emissions from each kiln,K-1 and K-2, shall not exceed 39.141bs/hour
at a production rate of 29 tons/hour(4.1 x P 1.61). The Permittee shall perform a semi-annual visual
inspection of kiln emissions ductwork and a semi-annual visual inspection of the kiln's fuel
combustion system,and send semiannual summary reports to DAQ.
APPEARED IN COMPLIANCE —Facility operates on NG with No. 2 fuel oil as backup. The
PM emission rate determined from the 9/13/16 test was 3.78 lb/hr. The facility was operating at
25.17 TPH with DLA control. The calculated PM emission limit at this operating rate is 35.6 lb/hr.
This demonstrated emission rate is for filterable PM only, but since it is so low it is unlikely the
Total PM emission rate would exceed the limit. During the inspection, I reviewed I&M records
documenting internal and external inspections that were conducted semi-annually(K-2: 1/26/18,K-
1: 1/30/18). The most recent semiannual report was received on time and appeared complete and
valid.
B. 15A NCAC 2D .0516 SULFUR DIOXIDE CONTROL REQUIREMENT — Sulfur dioxide
emissions from each kiln, K-1 and K-2, and from rotary coatings dryer SD-1 shall not exceed 2.3
lbs/mmBtu heat input. For kilns K-1 and K-2, the Permittee shall monitor the sulfur content and
y the Btu content of the No. 6 fuel oil through fuel supplier certifications,no monitoring requirements
when using NG or No. 2 fuel oil. Keep quarterly log of fuel certs when using No. 6 fuel oil.
APPEARED IN COMPLIANCE — K-1 and K-2 are normally and currently operating on NG.
Since January 2010 the facility has only used 42 fuel oil as back up fuel during NG curtailment.
The last shipment of No. 6 fuel oil received at the facility (S= 1.36%) was in 2010 and none of it
has been combusted to date. The facility did burn approx. 12,600 gals of#2 fuel oil in Nov 2016
and Jan 2017 due to curtailment. The rotary coatings dryer SD-1 started operation in June 2005,
and is designed to operate solely on natural gas. AP-42 SOz emission factor for NG is 0.0006
lb/mmBtu.
C. 15A NCAC 2D .0521 VISIBLE EMISSIONS CONTROL REQUIREMENT — Visible
emissions from kilns K-1 and K-2 shall not be more the 20 percent opacity. The Permittee shall
observe the kiln emission points once each month for normal vs abnormal, and submit semiannual
summary rpts to DAQ.
APPEARED IN COMPLIANCE — During the inspection, K-1 and K-2 were operating with 0%
VE from the DLA stacks. The facility continues to log weekly VE observations (surpassing the
monthly requirement), and all have been "normal". The most recent semiannual report was
{ received on time and appeared complete and valid.
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D. 15A NCAC 2D .0524 NEW SOURCE PERFORMANCE STANDARDS SUBPART UUU —
For the Rotary coatings dryer(SD-1): VE shall not be greater than 10%,the Permittee shall observe
the source daily for anv VE; the Permittee shall inspect and maintain the rotary coatings dryer in
accordance with the manufacturer's recommendation and shall perform a semi-annual internal
inspection for deterioration,damage and leaks; and submit semi-annual summary rpts to DAQ.
APPEARED IN COMPLIANCE — During the inspection I reviewed the logbook of daily VE
observations; all were recorded as "normal," which was defined by the facility as "No Visible
Emissions." The unit was not operating during the inspection. The records appeared complete and
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valid and the time of each observation is now being recorded as advised during the previous
inspection. I also reviewed records of semi-annual inspections on the dryer (7/14/17. 1/29/18),
which appeared complete and valid. The most recent semi-annual report was received on time and
appeared complete and valid.
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E. 15A NCAC 2D .0524 NEW SOURCE PERFORMANCE STANDARDS SUBPART 000 —
For the primary crushing plant scalp screens,jaw crushers, and conveyors (ID Nos. PC-3 through ;
PC-10), the Permittee shall comply with the notification and recordkeeping requirements: dates of
construction, anticipated startup and actual startup; performance test data; and excess emissions
reports. The VE shall not be greater than 10%, except for crushers not greater than 15%; Permittee
shall observe the individual sources monthly for normal vs abnormal VE. Permittee shall submit
semiannual summary rpts to DAQ.
APPEARED IN COMPLIANCE — Sources PC-4, 6, 8 & 9, have not been installed; therefore,
NSPS notifications have not been submitted. All notifications have been submitted for sources PC-
3, 5, 7, & 10. These sources were not operating during the inspection, except for the conveyor
transporting material into the clay grinding building (PC-10). Monthly observation records were
complete, indicating "normal," where normal is defined by the facility as <10% opacity. These
sources are grouped in the logbook, but VE observations are made at the individual sources. Mr.
Wallace stated that he has been to smoke school as well as Mr. Meggs, so they now know what
10% opacity looks like. The most recent semiannual report was received on time and appeared
complete and valid.
F. 15A NCAC 2D .0524 NEW SOURCE PERFORMANCE STANDARDS SUBPART 000 —
There are two clay grinding operations including: plant scalp screens, finish screens, hammer mill,
storage bins, feeders and conveyors (ID Nos. CG-2 through CG-8 and CG-10 through CG-28); and
scalp screens, finish screens, hammer mill, storage bins, feeders and conveyors (ID Nos. CG-30
through CG-55). The non-stack VE shall not be greater than 10%, except for crushers not greater
than 15%. Permittee shall monthly observe building openings for any VE or source stacks for
normal vs abnormal VE. Permittee shall submit semiannual summary reports to DAQ.
APPEARED IN COMPLIANCE — The facility has chosen to observe the building openings
monthly for any VE. There are two openings to each half of the grinding building(the building has
a dividing wall down the center and two separate clay grinding operations reside in same building).
One conveyor in the grinding operation is in separate building (milling bldg) from the rest of the
subject sources which require VE observations. Observations are made at both openings, for each
side of the grinding building, and the mill building, monthly. The monthly observation records all
indicated "normal," which is then defined by the facility as "No Visible Emissions." Most of the
sources in the two buildings were operating during the inspection and zero (0) visible emissions
were observed from the building openings. The most recent semiannual report was received on
time and appeared complete and valid.
G. 15A NCAC 2D .0524 NEW SOURCE PERFORMANCE STANDARDS SUBPART 000 -
For the loam/sawdust preparation area, loam screen, loam crusher, storage bunker, sawdust screen,
and conveyors (ID Nos. LS-2 through LS-12), non-stack VE shall not be greater than 10% except
for crushers not greater than 15%; Permittee shall observe building openings monthly for any VE.
Permittee shall submit semiannual reports to DAQ.
APPEARED IN COMPLLANCE —There are two openings to each half of the grinding building.
Observations are made at both openings, for each side of the grinding building, monthly. The
monthly observation records all indicated "normal," which is then defined by the facility as "No
Visible Emissions." The sawdust operations were operating during the inspection and zero (0)
visible emissions were observed from the building openings. The most recent semiannual report
was received on time and appeared complete and valid.
H. 15A NCAC 2D .0524 NEW SOURCE PERFORMANCE STANDARDS SUBPART Kb —The
Permittee shall maintain records showing the dimension and capacity of storage vessels.

APPEARED IN COMPLIANCE — Tanks T-1 thru T-4 currently listed as subject to this rule all
contain petroleum products such as fuel oils for off road use, and Tank T-5 contains an additive that
is, according to Mr. Wallace, a derivative of pine sap used as a binding agent. These tanks do not
appear to be subject to NSPS Kb because they contain a substance with a vapor pressure way less
than the triggering requirement in the NSPS. It appears that NSPS Subpart Kb has been applied in
error to vessels T-1 thru T-5.
I. 15A NCAC 2D .1100 TOXIC AIR POLLUTION EMISSION LIMITATIONS AND
REPORTING REQUIREMENT — According to the air toxic compliance demonstration, TAP
emissions will not exceed the established emission limits if they are controlled by limiting the
amount of clay and additives processed in each of the kilns, K-1 and K-2, to 58,000 lbs/hour (29
TPH). Quarterly summary reporting to DAQ.
APPEARED IN COMPLIANCE The facility is currently operating K-1 and K-2 at approx. 11
TPH each. The highest hourly rate in the last 12 months was approx. 15 tons for K-2 and was
approx. 11 tons for K-1,below the permit limits. Quarterly reports appear complete and valid.
J. 15A NCAC 2D .1806 CONTROL AND PROHIBITION OF ODOROUS EMISSIONS — The
Permittee shall prevent odorous emissions from the facility from causing or contributing to
- objectionable odors beyond the facility's boundary.
APPEARED IN COMPLIANCE No odor, associated with this facility, was noticed when
entering or exiting the property. DAQ has not received any complaints since the previous
inspection. Mr.Wallace stated that the facility has not received any odor complaints.
K. 15A NCAC 2Q .0317 AVOIDANCE for MACT—In order to remain classified minor source for
HAPS and avoid MACT requirements, facility emissions of HAPS shall be less than 10 TPY of
each HAP and 25 TPY Total HAPS. Monitoring, Recordkeeping and reporting requirement are
established in permit to demonstrate facility remains minor source for HAPS. These requirements
are summarized below as followed:
Monitoring and Recordkeeping Requirements.
(1) The Permittee shall operate the DLAs (CD-K1 and K2) when Kilns (K-1 and K-2) are
operating, except during periods of startup, shutdown, or malfunction or during operation in
bypass mode for routine maintenance of the DLAs.
(2) The DLAs have maintain an adequate amount of limestone.
(3) The same grade of limestone used during the performance shall be used.
(4) The Permittee shall maintain the limestone feeder rate settings at or above the settings
established during the performance test. Monitor and record each day.
(5) The Permittee shall monitor the bypass damper position and document when record when Kilns
are operated when damper is open.
(6) Permittee shall record the production rate on a fired product basis for each Kiln and keep
records.
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APPEARED IN COMPLIANCE — Based on prior source test for each Kiln, the BF and HCL
emissions have been measured less than 10/25 TPY. This measurement was made with the DLAs
F operating to reduce the HAP emissions. The control of HAPS by the DLAs reduce the actual
emissions less than 10/25 TPY RAPS. The facility records were observed and indicate that when
Kilns are operating the DLAs are in uses. The records indicate that the limestone is tested to
demonstrate quality. The limestone levels are monitored daily to insure the amount and feed rate of
limestone is adequate. The bypass vent is observed each day and records indicate it is hard locked
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to prevent it be place in a bypass mode. The facility has submitted semi-annual report to
summarizes all requirement this rule. The Most recent report was received on 1/27/2018 and
indicated compliance.
L. 15A NCAC 2Q .0711 PERMIT REQUIREMENTS FOR TOXIC AIR POLLUTANTS — The
Permittee shall operate the facility in such a way that any listed TAP emissions from the facility do
not exceed TPERs.
APPEARED IN COMPLL4,NCE—Based on the current and previous 12 months' operating rates,
and sources of raw material, Triangle Brick TAP emissions are below.the listed TPERs.
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M. 15A NCAC 2Q .0317 AVOIDANCE CONDITION FOR 15A NCAC 2D .0530 PREVENTION
OF SIGNIFICANT DETERIORATION — The sulfur dioxide emissions from each kiln shall be
less than 250 tons per 12-month period. K-1 and K-2 production throughput is limited to 58,000
lbs/hour each and the amount of No. 6 fuel oil, with 2.1% sulfur, burned is limited to 920,000
gallons per 12-month period. Both kilns are required monthly to calculate and record S02
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emissions. K-1 has quarterly summary reporting of S02 emissions and fuel combustion quantities.
K-2 has semi-annual summary reporting of S02 emissions and fuel combustion quantities.
APPEARED IN COMPLIANCE— The facility burns NG with low sulfur No. 2 fuel oil as back
up only during NG curtailment. The facility was curtailed in Nov 2017 and Jan 2018 and burned
approx. 12,600 gals of fuel oil. S02 emissions thru June 2018 are expected to not exceed 250 tpy.
The highest hourly production rate for CY 2018, thus far, has been approx. 11 tons/hr. for K-1 and
12 TPY for K-2. Quarterly reports appear complete and valid.
N. PERMIT GENERAL CONDITION I.A and I.B — REPORTING REQUIREMENTS FOR
EXCESS EMISSIONS AND PERMIT DEVIATIONS: The facility is required to report excess
emission events and malfunctions that last more than 4 hours per the requirements of 15A NCAC
213 .0535.
APPEARED IN COMPLIANCE — Mr. Wallace stated that the facility has had no excess
emission/malfunction events and therefore no notification has been required.
O. PERMIT GENERAL CONDITION P-COMPLIANCE CERTIFICATION 3
REQUIREMENT: The facility is required to submit an Annual Compliance Certification(ACC)
report postmarked before March 1 of each year, stating compliance with all permit conditions or
noting any deviations during the previous calendar year.
APPEARED IN COMPLIANCE—The latest ACC report was received on 01/30/18 and appeared
complete and valid.
P. GENERAL CONDITION X—ANNUAL EMISSION INVENTORY REQUIREMENTS—The
permittee shall submit an Annual Emission Inventory postmarked on or before June 301 of each
r
year. "
APPEARED IN COMPLIANCE — The facility's 2016 AQEI was received on 06/29/2017 and
appeared to be complete and accurate. The next APEI is due on 6/30/18.
Q. PERMIT GENERAL CONDITION MM—FUGITIVE DUST CONTROL REQUIREMENT:
The Permittee shall not cause of allow fugitive dust emissions to cause or contribute to substantive
complaints or excess visible emissions beyond the property boundary.
APPEARED IN COMPLIANCE—Mr. Wallace stated that no dust complaints had been received
by the facility, and FRO has not received any dust complaints. There did not appear to be any
issues with fugitive dust from our observations on site.

7. NON-COMPLIANCE HISTORY SINCE 2010:
May 2017—NOD issued for late quarterly report submittal;report received 5/12/17
8. 112r STATUS:
The facility does not store any of the listed chemicals in amounts that exceed the threshold quantities.
Therefore,they are not required to maintain a written Risk Management Plan(RMP).
9. CONCLUSIONS AND RECOMMENDATIONS:
Based on the observations made during the 12 April 2018 compliance inspection, Triangle Brick Co-
Wadesboro appeared to be in compliance with the requirements in their current air permit.
Pink Sheet Issues:
'j Removed Gasoline Storage Tank IS-Tank from Insig. List and GACT CCCCCC status. Permit engineer
should tweak both the K-1 and the K-2 2D.0530 stips to make same,including reporting frequency
tPermit engineer should evaluate and remove NSPS Kb applicability to tanks T-1 thru T-5, as it appears they are not
subject due to vapor pressure of material stored in tanks
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