AQ_F_1900077_20170424_ST_RvwMemo (4)

DIVISION OF AIR QUALITY
April 24, 2017
MEMORANDUM
To: Patrick Butler, P.E.,Raleigh Regional Office
From: Shannon Vogel, Stationary Source Compliance Branch �V
Subject: Triangle Brick Company-Merry Oaks
Moncure, Chatham County,North Carolina
Facility M 1900077,Permit No. 06897T10
Particulate Matter,Hydrogen Chloride,Hydrogen Fluoride Testing of
Kiln K-3 Dry Limestone Adsorber
Performed February 9, 2017 by Environmental Resource Management(ERM)
Tracking No. 2017-053st
ERM performed EPA Method 5 for filterable particulate matter(PM) and EPA Method 26A for hydrogen
chloride(HCl)and hydrogen fluoride(HF) emissions. Per the stack test observation by Stan Williams,
RRO, this testing is a"retest... of the initial performance test that the facility initially performed on
September 12,2016, in which they failed to meet the limit for filterable PM." The February test results
are acceptable and demonstrate compliance with the applicable emissions limits as discussed below.
Emissions Source ID K-3 is a natural gas/No. 2 fuel oil/No. 6 fuel oil-fired brick tunnel kiln controlled by
CD-K3 dry lime cascade adsorber unit. The maximum permitted brick production rate is 29 tons per hour
(tph). Triangle Brick reported an average production rate of 26.2 tph during testing. The test results are
tabulated below. The pounds per day(lb/day)results are based on 24 hours per day.
The following regulations apply to Kiln K-3:
15 NCAC 2D .0515 Particulates From Miscellaneous Industrial Processes which limits PM to 36.6
pounds per hour(lb/hr)based on the production rate during testing of 26.2 tph.
15A NCAC 2D .11091126) Case-by-Case Maximum Achievable Control Technology(MALT)which
limits the HCl-equivalent to 21.19 lb/hr(K-1, K-2 and K-3 combined) and filterable PM to 0.17
pounds per ton of brick produced(lb/ton).
15A NCAC 2D .1100 Control of Toxic Air Pollutants which limits HCl emissions to 115.44 lb/hr and
HF emissions to 878.11 lb/day and 41.21 lb/hr.
Pollutant Test Results Emission Limit Standard Compliance
4.171b/hr 36.61b/hr 2D .0515 Yes
Filterable PM 0.16 lb/ton 0.17 lb/ton 2D .1109 Yes
Case-by-Case MACT
HCl 0.13 lb/hr 115.44 lb/hr' 2D .1100 Yes
HF 0.21 lb/hr 41.21 lb/hr' 213 .1100 Yes
4.94 lb/day 878.11 lb/day' 213 .1100 Yes
HCl-Equivalent 0.42 lb/hr 21.19 lb/hr' 2D .1109 Yes
Case-by-Case MACT
1. The emissions limits apply to combined emissions from all the kilns.
The test results demonstrated compliance with the 2D .1109 case-by-case MACT permitted PM emission
limit. If you have any questions, please contact me at shannon.voaelLnicdenngov or 919-707-8416.
cc: Central Files, Chatham County IBEAM Documents - 1900077