AQ_F_0400043_20170406_ST_RvwMemo

DIVISION OF AIR QUALITY
April 6, 2017
MEMORANDUM
To: Steven Vozzo,Fayetteville Regional Office
�00From: Shannon Vogel, Stationary Source Compliance Branch
Subject: Triangle Brick Co. -Wadesboro
Wadesboro,Anson County,North Carolina
Facility ID 0400043, Permit No. 08179T09
Total Particulate Matter and Hydrogen Chloride and Hydrogen Fluoride
Emissions Testing of Brick Kiln K-2 Performed September 13, 2016
Performed by Environmental Resource Management(ERM)
Tracking No. 2016-213st
ERM performed EPA Method 5 testing for filterable particulate matter(PM)and EPA Method 26A for
hydrogen chloride(HCI)and hydrogen fluoride (HF)emissions. The test results are acceptable and
demonstrate compliance with the applicable emissions standards as discussed below. Emissions Source
ID K-2 is a natural gas/No. 2 fuel oil/No. 6 fuel oil-fired brick tunnel kiln controlled by dry lime adsorber
(DLA) CD-K2. The maximum material output rate is 29.0 tons per hour.
15A NCAC 2D .0515 Particulates From Miscellaneous Industrial Processes and 15A NCAC 2D .1109
Case-by-Case Maximum Achievable Control Technology (MACT)for Brick Manufacturers apply to K-2.
213 .0515 limits total PM based on actual production rate. Permit Condition 2.1.A.4.b establishes limits
for the combined emissions from brick kilns K-1 and K-2 for filterable PM,HCI, and HF. The HCl and
HF limit is expressed as HCl equivalent(HCleq)as defined in the permit. The combined limit is 0.17
pounds per ton(lb/ton)for filterable PM and 9.455 pounds per hour(lb/hr) for HCleq. The average
production rate during testing was 25.17 tons per hour for which the 2D .0515 limit is 35.6 lb/hr.The test
results are acceptable and are tabulated below.
Pollutant Test Results Limit Standard Compliance
Filterable PM 3.78 lb/hr 35.6 lb/hr 2D .0515 Yes'
0.15 lb/ton 0.17 lb/ton 2D .1109 Yes
HCI 0.152 lb/hr --- ---
HF 0.121 lb/hr ---
HCI equivalent' 0.325 lb/hr 9.455 lb/hr3 2D .1109 Yes
(K-1 and K-2 combined)
Process Rate 25.17 ton/hr 29.0 ton/hr --- ---
1. 2D.0515 compliance is demonstrated on filterable PM results only due to margin of compliance.
2. HCl equivalent calculated based on HCl and HF results(HCI+HF(RfHc1/RfHF)
3. 2D .1109 limits the combined emissions from K-1 and K-2.
The audit sample analysis was performed and found to be acceptable for HCI and HF. Compliance was
indicated. Please contact me at 919-707-8416 or shannon.vo ee1L&ncdenr.gov if you have any questions
regarding the results of this review.
cc: Central Files, Anson County
IBEAM Documents -0400043