AQ_F_1900077_20170512_CMPL_NOV

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
Air Quality MICHAEL A. ABRACZINSKAS
ENVIRONMENTAL QUALITY Director
May 12, 2017
Mr. Howard Brown Jr., CEO
Triangle Brick Company
6563 NC Highway 55
Durham,North Carolina 27713-9413
Subject: Notice of Violation—Stack Test Results
Source Tested: Kiln K-3 Dry Limestone Adsorber
Triangle Brick Company—Merry Oaks
Moncure, Chatham County,North Carolina
Cntyprem. No. 1900077; Current Air Permit No. 06897TI0
Fee Class: Title V; Re-test Conducted—February 9, 2017
Tracking No. 2017—053ST
Dear Mr. Brown:
Air Quality Permit No. 06897T10 for your facility in Merry Oaks, North Carolina requires that the
facility comply with 1120) Case-by-Case MACT standards for brick manufacturers by August 21, 2016,
and that initial compliance testing be performed within 180 days of that date. On September 12, 2016, the
facility performed the required initial compliance testing on Kiln 3. The results of that test were reviewed
by the Division of Air Quality's Stationary Source Compliance Branch(DAQ-SSCB) and demonstrated an
exceedance of the filterable particulate matter in units of pounds of pollutant per ton of fired brick. This
failed particulate emission test represents a violation of Section 2.1(C)(6)(b)(i) of the subject air permit.
Subsequently,Triangle Brick conducted additional particulate matter emissions testing on Kiln 3 on
November 3, 2016, but once again the preliminary test results indicated an exceedance of the applicable
1120) emission limit. Triangle Brick then notified DAQ,through their consultant,that a determination had
been made that the excess particulate emissions were not coming from the kiln itself, but were being
generated by the emission control device, a dry limestone adsorber or DLA, and that a DLA representative
was being called to the site to assist in trouble shooting the problem.
After corrective actions were taken, Triangle Brick scheduled a full 1126) retest of Kiln 3 for
February 9, 2017. The results of this test were reviewed by DAQ-SSCB and were deemed acceptable to
demonstrate compliance with the 1120) Case-by-Case MACT limits for filterable particulate matter,
hydrogen chloride, and hydrogen fluoride emissions.
However, DAQ is still concerned because of the narrow margin of compliance by which Kiln 3 was
able to meet the 1120) emission limit for particulate matter. Additionally, the test results show a trend of
particulate matter emissions increasing with each subsequent test run. If you calculate the particulate matter
emission rate for each test run in units of pounds per ton of fired brick, you get the following results for the
February 9,2017 test program: Run 1: 0.1431bs/ton;Run 2: 0.1461bs/ton;and Run 3: 0.188 lbs/ton. These
State of North Carolina I Environmental Quality I Air Quality
Raleigh Regional Office 1 3800 Barrett Drive I Raleigh,North Carolina 27609
919 791 4200 T 1 919 8812261 F

Howard Brown
May 12, 2017
Page 2 of 2
calculations are based on Triangle Brick's reported average production rate of 26.2 tons per hour during the
test period. While the average filterable particulate matter rate for the retest is below the 0.17 pounds/ton
limit in your permit, it also represents a particulate matter emission rate of 94 percent of the emission limit
with the third test run showing an exceedance of the 1120) limit. Therefore, by this Notice, DAQ is
requiring Triangle Brick to perform another EPA Method 5 performance test for filterable particulate matter
from Kiln 3 by February 9, 2018. If significant changes are made to the DLA system prior to next
performance test,Triangle Brick shall concurrently test for hydrogen chloride and hydrogen fluoride during
the required particulate emissions testing on Kiln 3.
Please submit a written response to this Notice of Violation by June 7,2017,indicating actions
taken or planned by your company to ensure future compliance the 1120) emission limits defined in
your air permit and confirming your plans to retest Kiln 3 by February 9, 2018. This violation and/or
any future violations are subject to the assessment of civil penalties as per the authority of North Carolina
General Statute 143-215.114.
See attached memorandums dated January 20, 2017 and April 24, 2017, for additional information
related to the Division of Air Quality's review of the September 12,2016 and February 9,2017 performance
test results, respectively. If you have any questions related to this matter, please do not hesitate to contact
Stan Williams, Environmental Engineer, or Steve Hall, Compliance Supervisor, at(919) 791-4200.
Sincerely,
pc�tj
Patrick Butler, P.E., Regional Supervisor
Division of Air Quality, NC DEQ
Attachments
cc: RRO Files