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Home My WebLink AboutAQ_F_1900077_20160823_ST_ProtRvw (4) PAT MCCRORY Governor DONALD R. VAN DER VAART Secretory Air Quality SHEILA C. HOLMAN ENVIRONMENTAL QUALITY Director August 23, 2016 Mr.Howard P.Brown,Jr. Executive Vice President&COO Triangle Brick Company-Merry Oaks 6523 NC Highway 55 Durham,North Carolina 27713-9436 Subject: Triangle Brick Company-Merry Oaks Plant,Facility ID 1900077, Tracking No. 2016-204ST Merry Oaks, Chatham County,North Carolina,Air Permit No. 06987T10 Protocol for Emissions Testing of Brick Tunnel Kiln(ID No.K-3) Filterable Particulate(PM),Hydrogen Chloride(HCl) and Hydrogen Fluoride(HF) Test To Be Performed by Environmental Resources Management(ERM) Test Date: Week of September 12,2016 Dear Mr.Brown: The North Carolina Division of Air Quality(DAQ)has reviewed the subject protocol submittal for emissions testing of brick tunnel kiln K-3. The proposed testing is acceptable to demonstrate compliance with the applicable emissions standards. The source to be tested is a natural gas/No. 2 fuel oil/No. 6 fuel oil-fired Brick Tunnel Kiln(29.0 tons per hour material output rate, 42.8 million Btu per hour heat input rate). Brick tunnel kiln K-3 is controlled by dry limestone cascade adsorber(DLA) CD-K3. Testing will be performed at the CD-K3 exhaust stack during normal production. The standard that applies to K-3 is 15A NCAC 2D .1109 112(J) Case-by-Case MACTfor Brick Manufacturers. Permit Condition 2.1.A.6.b lists the Case-by-Case MACT limits for Filterable PM and HCl-equivalent. K-3 is also subject to 15A NCAC 2D .1100 Toxic Air Pollutant Emission Limitation and Requirements in permit section 2.1.A.5.. The table below lists the pollutants and proposed test methods. Brick Tunnel Kiln K-3 —Pollutants and Test Methods EPA Target Method Run Time Standard Emissions Limit ■ Volumetric Flow Rate 1,2,3A, 3 runs,60 minutes each ■ Molecular Weight and 4 Concurrent with Methods --- --- ■Moisture Content 5/26A ■Filterable Particulate(PM) See permit condition ■ Hydrogen Chloride(HC1) 15A NCAC 2D .1109 2.1.A.6.b ■ Hydrogen Fluoride(HF) 5/26A 3 runs 60 minutes each 112(J) Filterable PM 0.17 lb/ton ■ Reported as Hydrogen HCl-equivalent 21.19 lb/hr Chloride-equivalent 15A NCAC 2D .1100 Toxic air pollutants (HCl equivalent) See Section 2.1.A.5 Note: The tester must verify the absence of cyclonic flow as described in Section 11.4 of U.S.EPA Method 1. State of North Carolina I Environmental Quality I Air Quality 1641 Mail Service Center 1217 W.Jones Street,Suite 4000 1 Raleigh,NC 27699-1641 919 707 8400 T Mr. Howard P. Brown,Jr. -Executive Vice President&COO August 23, 2016 Page 2 (Triangle Brick Company-Merry Oaks,Kiln K-3 -HCl and HF Emissions Testing) ERM proposes using a combined EPA Method 5/26A sampling train for PM, HC1, and HF. The proposed combined method is acceptable provided the EPA Method 26A Teflon filter support is used(the alternative Teflon probe liner, cyclone, and filter holder are not acceptable). Also the probe and filter temperature requirements of both EPA Method 5 and Method 26A must be met. Please note that the detection limits for some of the proposed methods are based on actual source parameters. No estimated detection limits are listed in the protocol. Therefore,the responsibility will remain with Triangle Brick and the tester to ensure that the minimum method detection limits will be low enough to demonstrate compliance with the applicable emissions limits. The result cannot be reported as zero. The result must be reported as less than the method detection limit determined from the test. Note that audit sample analysis is required for EPA Method 26A. ERM has submitted an audit sample order request. The sample must be present for inspection on request during the test period. For additional information please see this EPA web page http://www.epa.goN,'ttn/emciemail.html#audit. The target process rate for testing is 29 tons per hour. Please note representative testing is considered to be 90%or above maximum production rate. Additional testing or an adjustment to the permitted maximum production rate may be required if the test period process rate is less than the 90%. The test period process rate information must be included in the report with the applicable control system operation parameters (i.e. source and grade of limestone,pressure drop and limestone feed rate). Approval of the proposed testing methods does not exempt the tester, in any way, from the minimum requirements of the applicable test methods. Any deviations from the applicable methodologies not specifically addressed in this letter remain subject to the approval of the Division of Air Quality. If there are questions concerning this matter, please contact me at(919)707-8415 or gregg.onealAncdenngov. Sincerely. v Thomas G. O'Neal, III,P.E., Environmental Engineer Division of Air Quality,NCDEQ cc: Anthony King, Environmental Resources Management (ERM)—Franklin, TN Patrick Butler,P.E., Raleigh Regional Office Central Files, Chatham County IBEAM Documents - 1900077