AQ_F_0400043_20170818_CMPL_InspRpt

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NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY Triangle Brick Co-Wadesboro
NC Facility ID 0400043
Inspection Report County/FIPS:Anson/007
Date: 09/15/2017
Facility Data Permit Data
Triangle Brick Co-Wadesboro Permit 08179/T09
US Hwy 52 Issued 11/14/2016
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-Significant
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 CEO CEO NSPS: Subpart 000,Subpart UUU
[phone] [phone] [phone]
Compliance Data
Comments: Inspection Date 08/18/2017
L Inspector's Name Heather Carter
q� ..:� Operating Status Operating
Inspector's Signature: �p Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: 111g17 On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2015 13.09 22.49 9.43 4.54 42.01 10.90 13802.45
2014 13.33 22.31 9.37 4.61 42.81 11.11 14082.36
2013 14.02 21.32 8.96 4.04 41.01 11.90 3696.26
*Highest HAP Emitted(in pounds)
Five Year Violation History:
None
Performed Stack Tests since last FCE:
Date Test Results Test Method(s) Source(s)Tested
09/13/2016 Compliance Method 26A,Method 5 K-2
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 side of Wadesboro, turn
right, following US 52 north. Go approximately 3.5 miles and turn right into the first facility entrance;
the office is on the left. Check opacities prior to entering(kiln stacks,openings in bldg with grinders).

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.
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 on 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 18 August 2017, I, Heather Carter, FRO DAQ, met with Mr. Nathan Wallace, the Plant Manager, to
conduct the annual compliance inspection. Triangle is currently operating Kiln#1 (K-1) and Kiln#2 (K-
2) at approx. 11 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 promulgated NESHAP 57 (Brick MACT).
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.
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:
-I PERMITTED SOURCES
E yitR` OU ' , 0ce
Description AID No. ti"t
E , t .
Two Brick Tunnel Kilns
{ K-1 One natural gas/No.2 fuel oil/No. 6 fuel CD-Kl Dry Limestone
2D.1109 Case-by-Case oil-fired Brick Tunnel Kiln(29.0 tons per Adsorber(DLA)
MACT hour material output rate,42.8 million Btu
Op on NG w/DLA;0%VE per hour heat input rate)
K-2* One natural gas/No. 2 fuel oil/No. 6 fuel CD-K2 Dry Limestone
2D.1109 Case-by-Case oil-fired Brick Tunnel Kiln(29.0 tons per Adsorber(DLA)
MACT hour material output rate,42.8 million Btu
O on NG w/DLA• 0%VE per hour heat input rate)
Rotary Coatings Dryer
_ SD-1 One natural gas-fired Rotary Coatings Dryer N/A N/A
NSPS LT TIJ (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
l Not op/2 Not installed
PC-3 and PC-4 Two scalp screens N/A N/A
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 O00
Not Operating
PC-8 One conveyor under PC-4 and PC-6 N/A N/A
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
Fmtsslon Source Control Control W
Descption Duce � � bescriti
Two Secondary Clay Grinding Plants and Associated Conveyances
CG-1 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
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
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
O erating; 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
NSPS 000
O erating; 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 rating
CO-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
Overatinz. 0%VE
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
O eratin ;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
NSPS 000
O eratia ; 0%VE
CG-43 One conveyor belt over storage bins N/A N/A
NSPS 000
Operating;0%VE
CG-44 through CG-48 Five storage bins N/A N/A
NSPS 000
Operatiniz, 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
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
LS-2 One conveyor from loam/sawdust feeder to N/A N/A
NSPS 000 finish screens
Operating;0%VE
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
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
LS-10 One sawdust screen N/A N/A
NSPS 000
O eratin •0%VE
LS-11 One conveyor to storage bins N/A N/A
NSPS 000
Operating; 0%VE
LS-12 One oversize conveyor from sawdust screen N/A N/A
NSPS 000
Operating; 0%VE
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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
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 I "A"storage tank
PERMIT EXEMPT EMISSION SOURCES:
IS-Tank 3,000 gallon above ground gasoline storage tank

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 39.14 lbs/hour
at a production rate of 29 tons/hour(4.1 x P°67). 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: 7/19/16,
1/20/17, 7/10/17; K-1: 2/22/17, 7/10/17). 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 Pernttee shall monitor the sulfur content and
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 #2 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. No log book required since No. 6 fuel oil has not been combusted.
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 S02 emission factor for NG is 0.0006 lbhmnBtu.
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.
D. 15A NCAC 2D .1109 112j CASE-BY-CASE MACT (Brick) — The compliance date was
4 September 2016. Must meet a filterable PM limit of 0.17 lb/ton total from the kilns, and an HCL-
equivalent (HCLe) emission rate of 9.455 lbs/hr total from both kilns. Source test required within
180 days after compliance date. Must maintain daily records for: limestone levels in storage bins
and hopper, limestone feeder settings, bypass damper position, and visible emission observations
(may decrease to weekly if 0%VE is documented for at least 30 consecutive days). Must maintain
monthly records showing that limestone is being replaced on same frequency as during ST. Must
maintain records of: grade and source of limestone is same as during ST, production, and bypass
percentage of time annually. NOCS due within 60 days of source test. Semi-annual summary
reporting.
APPEARED IN COMPLIANCE—The facility started the DLA on K-2 in August 2016, prior to
the 4 September 2016 compliance date. They conducted a source test for PM and HCLe on 13

September 2016. The NOCS was submitted on 31 October 2016. Kiln #1 was restarted on 6
February 2017 with the DLA in operation. The required records all appeared complete and valid,
except for the DLA bypass damper monitoring and recordkeeping. The permit requirement is to
monitor the position of the bypass damper at least every 15 minutes, recording the results in a daily
record. The facility has chosen to padlock the bypass damper in the closed position (meaning
exhaust stream always passes through the DLA) and it must be manually unlocked with a key and
the damper opened to bypass the DLA. I recommended to Mr. Wallace that the facility request to
modify this condition in their permit under the current modification request that is in-house with
DAQ. Otherwise, they would need to meet the monitoring and recordkeeping requirement as
currently stipulated in their permit. The facility is currently observing and recording that the
damper is locked on a daily basis. The facility has NOT operated in"bypass condition" at all since
starting operation on the DLAs. The facility ordinarily receives limestone every 4-6 weeks,but Mr.
Wallace stated they use the"low level" indicator light to verify that the hopper is adequately filled.
I asked him what would happen if the light came on before he got more in. He stated that the
indicator is.sufficiently high in the hopper that they would not run out before the delivery came. I
explained that he would need to do something in addition to verifying the light is not on if indeed
the light did come on (i.e. visually look into the hopper to verify there is an adequate amount),
otherwise, he would be required to record a violation in that the indicator is telling him there is not
an adequate amount in the hopper. The facility is still using the same grade and source of limestone
as when they tested. Records of their daily observations of the DLA stacks all showed zero (0) VE
so they decreased to weekly observations, which also all show zero (0)VE. Mr.Wallace stated that
they did not have a formal record of the monthly verification that the limestone is being replaced on
same frequency as during the source test, but that personnel dump the waste container daily and if
they noted a decreased amount they would tell him or the operator, and nothing like that has
happened. I explained that he would need to create a monthly record to show what he is telling me.
The most recent semi-annual report was received on time and appeared complete and valid.
E. 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
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 (7/18/16, 1/19/17,
7/14/17), which appeared complete and valid. The most recent semi-annual report was received on
time and appeared complete and valid.
F. 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

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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.
1 Wallace stated that he has been to smoke school as well as Mr. Meggs, so they now know what
Ji 10% opacity looks like. 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 —
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.
H. 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 anv VE.
Permittee shall submit semiannual reports to DAQ.
APPEARED IN COMPLIANCE —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.
I. 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 thm T-5.
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 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.
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 COMPLIANCE—Based on the current and previous 12 months' operating rates,
and sources of raw material, Triangle Brick TAP emissions are below the listed TPERs.
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
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 2016 and Jan 2017 and burned
approx. 12,600 gals of fuel oil. S02 emissions thru June 2017 are approximately 34.9 tons, far
below the limit. The highest hourly production rate for CY 2017, thus far, has been approx. 11
tons/hr for K-1. Quarterly reports appear complete and valid.
N. PERMIT GENERAL CONDITION LA and LB — 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
2D.0535.
APPEARED IN COMPLLANCE — 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
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 01/30/17 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 30' of each
year.

APPEARED IN — The facility's 2016 AQEI was received on 06/29/2017 and
appeared to be complete and accurate.
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 18 August 2017 compliance inspection, Triangle Brick Co-
Wadesboro appeared to be in compliance with the requirements in their current air permit.
Pink Sheet Issues:
None
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