AQ_F_0400043_20170502_ST_RvwLtr

JI, ROY COOPER
Governor
MICHAEL S. REGAN
^ Secretary
Air Quality MICHAEL A. ABRACZ tNSKAS
IngUractor
ENVIRONMENTAL QUALITY
J
2 May 2017
Howard Brown, Jr., CEO
Triangle Brick
6523 NC Highway 55
Durham, NC 27713
SUBJECT: Central Office Review of Source Test Results-Brick Tunnel Kiln—
Source ID No. K-2
Air Quality Permit No. 08179T09
Triangle Brick Co—Wadesboro
Facility ID: 0400043 Fee Class: Title V
Dear Mr. Brown:
The Division has reviewed your source test report that was received by our Central Office
on 1 November 2016. 15A NCAC 2D .1109: §1120); Case-by-Case MACT for Brick
Manufacturers - Filterable PM, Hydrogen Chloride (HCI), Hydrogen Fluoride (HF), and HCl
equivalent source testing of natural gas/No. 2 fuel oil/No. 6 fuel oil-fired Brick Tunnel Kiln (ID
No. K-2) which was conducted on 13 September 2016. On 6 April 2017, this Division
determined that the subject test performed at your facility was an acceptable source test. The
review indicates compliance with Air Permit No. 08179T09 for this source. A copy of the
determination memorandum, issued by Ms. Shannon Vogel, of the N.C. Division of Air Quality,
Stationary Source Compliance Branch, is attached.
Note that the 1120) Case-by-Case MACT also requires parametric monitoring
values/ranges to be established during source testing, and that the facility keep records of these
monitored parameters in order to demonstrate continuous compliance. Stipulation 2.LAA.c.iii in
your air quality permit states that, "The Permittee shall use the data from the limestone feeder
during the performance test to establish the operating limit for the limestone feeder setting at the
DLAs.... " The parameters established during this source test were as follows: DLA (ID No. CD-
K2) limestone feedrate was set at 59 lb/hr; the DLA's peeling drum was set to a 2 minutes on/2
minutes off cycle and the screw was set to a 30 minutes on/30 minutes off cycle; and the
limestone used during testing was a 3/8 inch "Chemical" grade stone. Additionally, the DLA
bypass damper was locked in the closed position during this source test, in agreement with your
current permit which requires emissions from the kilns to be routed through the DLAs except for
periods of routine maintenance, not to exceed 4% of the annual operating time. Therefore, you
are also required to monitor the damper position (and percentage of bypass time) in order to
demonstrate continuous compliance with the 1120) Case-by-Case MALT.
State ofNorth Carolina I Environmental Quality I Alr Quallty
Fayetteville Regional Office 1 225 Green Street,Suite 714 1 Fayetteville,North Carolina 28301
910 433 3300 T 1 9104857467 F

Triangle Brick
2 May 2017
j Page 2
Should you have any questions regarding this matter, please contact Mr. Jeffrey Cole,
Environmental Engineer, at(910) 433-3300, in the Fayetteville Regional Office.
3
1 erel
1 Steven F. Vozzo
4
Regional Air Quality Supervisor
NCDEQ, Division of Air Quality
I
SFV\jdc
Attachment: DAQ RCO review(1),dated 6 Apr 2017[2016-213ST]
cc:❑FRO Files(with attachment)
State of North Carolina I Environmental Quality I Air Quality
Fayetteville Regional Office 1 225.Green Street,Suite 7141 Fayetteville,North Carolina 28301

ECIVE
DIVISION OF AIR QUALITY APR 112917
April 6,2017
iJ�IVro
MEMORANDUM FAYETfEVILLE REGIONAL OFFI(;1
To: Steven Vozzo,Fayetteville Regional Office M t
From: Shannon Vogel, Stationary Source Compliance Branch /1rY W O
Subject: Triangle Brick Co.-Wadesboro ttt
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.
2D .0515 limits total PM based on actual production rate. Permit Condition 2.LAA.b establishes limits
for the combined emissions from brick kilns K-1 and K-2 for filterable PM,HCI, and BY The HCI and
HF limit is expressed as HCI 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 35.61b/hr.The test
results are acceptable and are tabulated below.
Pollutant Test Results Limit Standard Compliance
Filterable PM 178 ib/ttr 35.6 lb/hr 2D .0515 Yes'
0.15 lb/tou 0.17 Wren 2D .1109 Yes
HCI 0.152lb/hr --- --_ ---
HF 0.121lb/hr ___ ---
I ICI equivalents 0,325 lb/hr K-1 andd K 9 -2 combined) 2D .1109 Yes
Process Rate 25.17 ton/fir 29.0 ton/hr _-.
1. 2D.0515 compliance is demonstrated on filterable PM results only due to margin of compliance.
2. IICI equivalent calculated based on HCl and HF results(HCI+HF(Rfnn/Rfrm)
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 meat 919-707-8416 or shannon.vogel a),ncdenr.eov if you have any questions
regarding the results of this review.
cc: Central Files,Anson County
IBEAM Documents -0400043
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