AQ_F_0400043_20160913_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY Triangle Brick Cc -Wadesboro
NC Facility ID 0400043
Inspection Report County/F1PS:Anson/007
Date: 09/23/2016
Facility Data Permit Data
Triangle Brick Co-Wadesboro Permit 08179/T08
US Hwy 52 Issued 9/4/2013
Wadesboro,NC 28170 Expires 8/31/2018
Lat: 35d 1.1463m Long: 80d 5.1235m Classification Title V
SIC: 3251/Brick And Structural Clay Tile Permit Status Active
NAICS: 327121/Brick and Structural Clay Tile Manufacturing Current Permit Application(s)TV-Minor
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP/Title V
Nathan Wallace Howard Brown,Jr. Howard Brown,Jr. MACT Part 63: Subpart JJJJJ
Plant Manager VP of Production and VP of Production and NSPS: Subpart 000,Subpart UUU
[phone] Engineering Engineering
[phone] [phone]
Compliance Data
Comments:
Inspection Date 09/13/2016
Inspector's Name Heather Carter
Inspector's Signature: 1 l p Operating Status Operating
Compliance Code Compliance-inspection
Date of Signature: 1�a3 I I ction Code FCE
On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PMIO *HAP
2014 13.33 22.31 9.37 4.61 42.81 11.11 14082.36
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2013 14.02 21.32 8.96 4.04 41.01 11.90 3696.26
2012 13.74 20.92 8.79 3.96 40.23 11.66 3626.00
*Hi nest HAP Emitted(in pounds)
Five Year Violation History:
None
Performed Stack Tests since last FCE:
None
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1. DIRECTIONS TO SITE:
i Triangle Brick is located on US 52 in Wadesboro, NC, Anson County. From FRO, take US 401 south to
US 74; turn right onto US 74 West. Follow US 74 thru Wadesboro. On the west side of Wadesboro,turn
right, following US 52 north. Go approximately 3.5 miles and turn right into the first facility entrance;
the office is on the left. Check opacities prior to entering(kiln stacks, openings in bldg with grinders).
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2. SAFETY: j
Safety glasses and shoes required;hard hat and ear protection optional. An operating kiln is hot to touch;
exiting bricks and cars are hot. Keep hands out of brick-making mechanisms, grinders and extruders.
3. FACILITY DESCRIPTION:
Triangle Brick Co. - Wadesboro is the second largest brick plant in the country. They make a variety of
bricks from clay and shale mined onsite. The material they mine is a consistent mixture of clay and shale.
As the material is mined, it is trucked up the hill to the facility where it is fed through a sizing grate. The
smaller material passes via conveyors to the storage shelter and the oversized material goes through a jaw j
crusher to reduce the size and then continues on to the storage shelter. There are two plants on site and
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the material from the storage shed feeds both. From the storage shelter material is scooped into a feeder,
run through a scalper (oversized material goes to hammer mill) then material (the consistency of
cornmeal) is conveyed to storage silos. From the storage silos the material is sent through two pug mills
in series where it is combined with water and mixed to an even consistency then fed through a machine
that extrudes the brick in a slab. The slabs are treated with a decorative coating (carrying agent is a
sawdust/loam mixture), cut into individual bricks and then loaded on a `car' for transport through the
dryer and kilns. Hydrogen Fluoride from the kilns is controlled by a dry lime adsorber (DLA) installed
on each kiln. The firing takes more than two days. After firing the bricks are packaged into skid loads
(by a very cool robot)and stored prior to purchase and shipment.
4. INSPECTION SUMMARY:
On 13 September 2016, Dan Thoma and I, Heather Carter, both from FRO DAQ, met with Mr. Nathan
Wallace, the Plant Manager, to conduct the annual compliance inspection and to observe the source test
for after control emission rates of PM and HCLe (HF +HCL) on kiln #2 (K-2). Triangle is currently
operating at -%60 capacity of Kiln #2 at approx. 21 tons/hr normally; Kiln #1 is not operating at this
time. The facility started operating the dry lime adsorber (DLA) on K-2 in August 2016 in advance of
their compliance date (September 4, 2016) for the case-by-case MACT for brick manufacturing. Their
current permit lists the DLAs as control on the kilns, but there are, currently, no permit required testing,
monitoring, recordkeeping and reporting requirements associated with the operation of these devices.
The current case-by-case MACT condition (including testing parameters) in their permit is based on
uncontrolled operation of the kilns. In a meeting with the facility prior to the planned source test date,
after receiving their testing protocol which included testing after control versus testing uncontrolled, we
discussed the facility's desired method of operation and actions for the facility to take to align their permit
with their desired operation. The facility plans to operate the DLAs on the kilns, test for after control
emission rates to show compliance with the case-by-case MALT, and subsequently (depending on test
results) apply for Title III (Hazardous Air Pollutants) synthetic minor (area source) classification, thus
avoiding the recently promulgated NESHAP 5J (Brick MACT). The facility submitted a minor
modification application requesting additional testing, monitoring, recordkeeping and reporting
requirements be added to their permit for the operation of the DLAs on the kilns. The facility received
approval to implement the proposed changes immediately(as of August 18, 2016),providing they comply
with the proposed terms, monitoring,recordkeeping and reporting conditions.
We started with the records review while we were waiting for the source test to start. Ms. Beth Barfield,
ERM consultant, and Mr. Ricky Merritt, TBC Director of Engineering, joined us partway through the
records review. Records appeared complete and in accordance with their current permit requirements.
One item noted, for the 2" year now, is that their "normal" VE description (NSPS 000) for several
sources is documented as <10% VE but their observers are not VEE certified. I advised Mr. Wallace to
describe "normal" in layman terms such that a non-certified observer could make a valid observation.
Additionally, the minor modification application submitted included additional monitoring (daily Method
22 on DLA exhaust) and recordkeeping (daily recording of limestone feeder rate setting and limestone

level in hopper)with regard to the DLAs that the facility had not yet implemented. I advised Mr.Wallace
to start immediately conducting all proposed monitoring and recordkeeping.
The source test was about to start so we walked to the rear of K-2 where the DLA is installed. We
discussed the DLA operation and factors like feeder rate settings and the interface they use (PLC) to see
the status and setting for the device. The PLC shows the feeder rate settings, but we couldn't see that it
showed the actual operating rate. There is a limestone low level indicator near the base of the hopper and
an alarm is set to activate(visual and audible)when/if the hopper level gets below the low level indicator.
Mr. Wallace stated that they anticipate refilling the hopper every 4-6 weeks, well before the level reaches
the low level indicator. A screw is installed on the DLAs to feed the limestone from the cascades (area
where the limestone is reacted with the exhaust stream) to the peeling drum where the outer layer of
limestone is "peeled off." The peeling (dust) is dropped to a collection container and the unreacted
limestone is blown back up to the hopper to pass through the cascades again. The feeder settings are:
peeling drum on 30 min, off 30 min; screw is on 2 min, off 2 min while peeling drum is on. The DLA
bypass damper is locked closed (meaning exhaust stream always passes through the DLA) and must be
manually unlocked and opened to bypass the DLA.
Dan Thoma was escorted by Mr. Tommy Meggs,kiln operator, on a tour of the kiln#2 plant. Mr. Meggs
began the tour with the Loam/Sawdust Preparation Operation which was actively screening sawdust only.
Neither Crushing Plant was operating, nor was there any clay grinding occurring due to the storage silos
being full. Material was being dropped from the silos onto a belt that conveyed the material from the
building over to the kiln #2 plant. I did not observe any VE leaving the building nor any while it was
transported along the covered conveyor belt over to the pug mills. I was really amazed just how clean
were the floor and the grounds outside leading into the plant. Mr. Meggs informed me that they waste
nothing and was quite proud of how clean they keep the plant. There was another conveyor that led into a
hopper that would reintroduce recyclable uncured brick scrap back into the pug mills. Here the material
coming into the plant was mixed and fed into extruder, coated, cut to size, and stacked. The whole
process is closely monitored but is almost completely automated. There are multiple optical eyes that if
the field is broken will stop the process, so it is important to be mindful when walking near the
machinery. The newly formed bricks were being loaded onto kiln cars and moved to a section in the plant
to dry. Later they would be fired in the kiln. The kiln runs 24 hours a day seven days per week and is
continuously feed with loaded kiln cars. Mr. Meggs stated that the kiln reuses the heat it produces with a
counter-current air exchanger and is very efficient. The kiln was firing natural gas at the time and does so
unless they are curtailed. I observed no visible emissions from the building vents and doors during the
facility tour.
After the 2°d test run started, Mr. Ricky Merritt drove Dan and I down into the mine and showed us the
ripping process and the pump that moves water collected in the mine to a settling pond outside the mine.
No hauling of mined material was occurring during the inspection. Mr. Merritt stated, originally, that the
pump (an associated non-emergency engine) remained in place because the mine was at its lowest point
and therefore rain water collected in the same area. Later he stated that the pump did move around. In a
follow-up correspondence the day after the inspection, Mr. Wallace indicated that the pump was no
longer on site as it had been moved to the Merry Oaks facility mine site.
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5. EMISSION SOURCES:
PERMITTED SOURCES
J3 e F'1P 0
se
Vra
A
Two Brick Tunnel Kilns
K-1 One natural gas/No. 2 fuel oil/No.6 fuel CD-K1 Dry Limestone
2D.1109 Case-by-Case oil-fired Brick Tunnel Kiln(29.0 tons per Adsorber(DLA)
MACT hour material output rate,42.8 million Btu
Not Operating per hour heat input rate)
K-2* One natural gas/No.2 fuel oil/No.6 fuel CD-K2 Dry Limestone
2D.1109 Case-by-Case oil-fired Brick Tunnel Kiln(29.0 tons per Adsorber(DLA)
MACT hour material output rate,42.8 million Btu
Op on NG wl 0%VE I per hour heat input rate)
Rotary Coatings Dryer
SD-1 One natural gas-fired Rotary Coatings Dryer N/A N/A
NSPS UUU (8.1 tons of clay per hour material input rate,
Not O eratin 0.3 million Btu per hour heat input rate)
Primary Crushing Plant and Associated Conveyances
PC-1 and PC-2 Two shale feeders N/A N/A
I Not op12 Not installed
PC-3 and PC-4 Two scalp screens N/A N/A
NSPS 000
3 Not OpI4 Not installed
PC-5 and PC-6 Two jaw crushers N/A N/A
NSPS 000
5 Not qp16 Not installed
PC-7 One conveyor under PC-3 and PC-5 N/A N/A
NSPS 000
Not Operating
PC-8 One conveyor under PC-4 and PC-6 N/A N/A
NSPS 000
Not installed
PC-9 One cross-over conveyor N/A N/A
NSPS 000
Not installed
PC-10 One shuttle conveyor N/A N/A
NSPS 000
Operating W/o%VE
lRoji Control Ivy
0, QWM M, P
Equsst '07
'VeiMpti so.ItV-V,
'ID ID N A
0 Jn
Two Secondary Clay Grinding Plants and Associated Conveyances
CG-1 One clay feeder N/A N/A
Not O era -
CG-2 One conveyor belt to scalping screen N/A N/A
NSPS 000
Not Operating

CG-3 One scalping screen N/A N/A
NSPS 000
Not Operating
CG-4 One return conveyor belt for oversize from N/A N/A
NSPS 000 screens
Not Operating
CG-5 One conveyor belt to hammer mill N/A N/A
NSPS 000
Not Operating
CG-6 One hammer mill N/A N/A
NSPS 000
Not Operating
CG-7 One conveyor belt under hammer mill N/A N/A
NSPS 000
Not Operating
CG-8 One conveyor belt to finish screens N/A N/A
NSPS 000
Not Operating
CG-10 through CG-13 Four finish screens N/A N/A
NSPS 000
Not Operating
CG-14 One fines conveyor belt under screens N/A N/A
NSPS 000
Not Operatiniz
CG-15 One conveyor belt to storage bins N/A N/A
NSPS 000
Not Operating
CG-16 One conveyor belt over storage bins N/A N/A
NSPS 000
Not Operating
CG-17 through CG-21 Five storage bins N/A N/A
NSPS 000
Not Operating
CG-22 through CG-26 Five feeders under storage bins N/A N/A
NSPS 000
Not Operating
CG-27 One conveyor in front of storage bins N/A N/A
NSPS 000
Not Operating
CG-28 One conveyor to pug mill N/A N/A
NSPS 000
Not Operating
CG-29 One clay feeder N/A N/A
� Not Operating
CG-30 One conveyor belt to scalping screen N/A N/A
NSPS 000
Not Operating
CG-31 One scalping screen N/A N/A
j NSPS 000
Not O eratin
CG-32 One return conveyor belt for oversize from N/A N/A
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NSPS 000 screen
j Not Operating
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CG-33 One conveyor belt to hammer mill N/A N/A
NSPS 000
Not Operating
CG-34 One hammer mill N/A N/A
NSPS 000
Not Operating
CG-35 One conveyor belt under hammer mill N/A N/A
NSPS 000
Not Operating
CG-36 One conveyor belt to finish screens N/A N/A
NSPS 000
Not Operating
CG-37 through CG-40 Four finish screens N/A N/A
NSPS 000
Not Operating
CG-41 One fines conveyor belt under screens N/A N/A
NSPS 000
Not Operating
CG-42 One conveyor belt to storage bins N/A N/A
NSPS 000
Not Operating
CG-43 One conveyor belt over storage bins N/A N/A
NSPS 000
Not Operating
CG-44 through CG-48 Five storage bins N/A N/A
NSPS 000
Op 0%VE at bldg. opening
CG-49 through CG-53 Five feeders under storage bins N/A N/A
NSPS 000
Op 0%VE at bldg. opening
CG-54 One conveyor in front of storage bins N/A N/A
NSPS 000
Op 0%VE at bldg. o enin
CG-55 One conveyor to pug mill N/A N/A
NSPS 000
Op 0%VE at bid . opening
Loam/ Sawdust Preparation Operation and Associated Conveyances
LS-1 Loam/sawdust feeder N/A N/A
Op 0%VE at bldg.opening
LS-2 One conveyor from loam/sawdust feeder to N/A N/A
NSPS 000 finish screens
Op 0%VE at bldg. opening
LS-3 One loam screen N/A N/A
NSPS 000
Not Operating
LS-4 One loam crusher N/A N/A
NSPS 000
Not Operating
LS-5 One oversize return conveyor from LS-3 N/A N/A
NSPS 000
Not Operating

LS-6 One oversize return chute N/A N/A
NSPS 000
Not Operating
LS-7 One fines conveyor belt under LS-3 to N/A N/A
NSPS 000 bunker belt conveyor
Not Operating
LS-8 One belt conveyor to bunker N/A N/A
NSPS 000
Op 0%VE at bldg. opening
LS-9 One storage bunker N/A N/A
NSPS 000
Op 0%VE at bldg.opening
LS-10 One sawdust screen N/A N/A
NSPS 000
Op 0%VE at bldg.opening
LS-11 One conveyor to storage bins N/A N/A
NSPS 000
Op 0%VE at bldg.opening
LS-12 One oversize conveyor from sawdust screen N/A N/A
NSPS 000
O 0%VE at bldg.opening
Nm�ss asMCI
� Emiss titc r H Control Control Device WW
Sit De Device Description
k -i
Above Ground Storage Tanks
T-1 One 24,000 gallon above ground No. 6 fuel N/A N/A
NSPS Kb oil storage tank
T-2 and T-3 Two 24,000 gallon above ground No.2 fuel N/A N/A
NSPS Kb oil storage tanks
T4 One 24,000 gallon above ground highway N/A N/A
NSPS Kb diesel fuel oil storage tank
T-5 One 24,000 gallon above ground Additive N/A N/A
NSPS Kb I "A"storage tank
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PERMIT EXEMPT EMISSION SOURCES:
irnY9SItF11$0un:6 be"aowti , ...
IS-Tank 3,000 gallon above ground gasoline storage tank
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6. APPLICABLE AIR QUALITY REGULATIONS:
A. 15A NCAC 2D .0515 PARTICULATES FROM MISCELLANEOUS INDUSTRIAL
PROCESSES—Particulate emissions from each kiln,K-1 and K-2, shall not exceed 39.14 lbs/hour j
at a production rate of 29 tons/hour(4.1 x P°67). The Permittee shall perform a semi-annual visual
inspection of kiln emissions ductwork and a semi-annual visual inspection of the kiln's fuel
combustion system, and send semiannual summary reports to DAQ.
APPEARED IN COMPLIANCE — Facility operates on NG with No. 2 fuel oil as backup. The
facility was testing K-2 for PM on the day of inspection, results are to be submitted by 13 October
2016. The result of the 14 March 2006 source test for PM (filterable only) was an emission rate of
2.03 lbs/hr operating at 23.47 tons/hr; this is an after DLA control emission rate. A 2005 permit
application citing before control emission rates shows a particulate emission rate of 3.48 lbs/hr at
29 tons/hr production. The facility normally operates at approximately 21 tph, however during the
inspection they were operating at approximately 25 tons/hr to facilitate optimal conditions for the
source testing that was occurring that day. During the inspection, I reviewed I&M records
documenting internal and external inspections that were conducted semi-annually (K-2: 1/13/16
and 7/19/16). Semiannual reports have been received on time and appear complete and valid.
B. 15A NCAC 2D .0516 SULFUR DIOXIDE CONTROL REQUIREMENT — Sulfur dioxide
emissions from each kiln, K-1 and K-2, and from rotary coatings dryer SD-1 shall not exceed 2.3
lbs/mmBtu heat input. For kilns K-1 and K-2, the Permittee shall monitor the sulfur content and
the Btu content of the No. 6 fuel oil through fuel supplier certifications,no monitoring requirements
when using NG or No. 2 fuel oil. Keep quarterly log of fuel certs when using No. 6 fuel oil
APPEARED IN COMPLIANCE — K-2 is currently operating on NG. Since January 2010 the
facility has only used#2 fuel oil as back up fuel during NG curtailment. The last shipment of No. 6
fuel oil received at the facility (S= 1.36%) was in 2010 and none of it has been combusted to date.
No log book required since No. 6 fuel oil has not been combusted. Kiln#1 ceased operation in Dec
2013 but only fired NG since 2010. The rotary coatings dryer SD-1 started operation in June 2005,
and is designed to operate solely on natural gas. AP-42 SO2 emission factor is 0.0006 lb/mmBtu.
C. 15A NCAC 2D .0521 VISIBLE EMISSIONS CONTROL REQUIREMENT — Visible
emissions from kilns K-1 and K-2 shall not be more the 20 percent opacity. The Permittee shall
observe the kiln emission points once each month for normal vs abnormal, and submit semiannual
summary rpts to DAQ.
APPEARED IN COMPLIANCE — During the inspection, K-2 was operating with 0% VE from
the DLA stack, with the exception of a very brief period of time when Dan and I saw light visible
emissions from the stack. We were not in the appropriate position to conduct a visible emissions
evaluation, so Dan proceeded to locate himself in the proper sun angle and distance and take
readings. By the time he was positioned, the visible emissions had returned to zero (0). Kiln #1
ceased operation in Dec 2013. I reviewed the log that documents weekly (surpassing the monthly
requirement) VE observations as normal. During a previous inspection, Mr. Meggs, the kiln
operator & VE observer, stated that he tries to make the observation during the "flash" (last 20
minutes before the car push)because that is the time when PM emissions would most likely be seen
if there were any. Semiannual reports have been received on time and appear complete and valid.
D. 15A NCAC 2D .0524 NEW SOURCE PERFORMANCE STANDARDS SUBPART UUU —
For the Rotary coatings dryer(SD-1): VE shall not be greater than 10%, the Permittee shall observe
the source daily for anv VE; the Permittee shall inspect and maintain the rotary coatings dryer in
accordance with the manufacturer's recommendation and shall perform a semi-annual internal
inspection for deterioration, damage and leaks; and submit semi-annual summary rpts to DAQ.

APPEARED IN COMPLIANCE — During the inspection I reviewed the logbook of daily VE
observations; all were recorded as "normal," which was defined by the facility as "No Visible
Emissions." The unit was not operating during the inspection. The records appeared complete and
valid and the time of each observation is now being recorded as advised during the previous
inspection. I also reviewed records of semi-annual inspections on the dryer(1/11/16 and 7/18/16),
which appeared complete and valid. Semi-annual reports have been received on time and appear
complete and valid.
E. 15A NCAC 2D .0524 NEW SOURCE PERFORMANCE STANDARDS SUBPART 000 —
For the primary crushing plant scalp screens,jaw crushers, and conveyors (ID Nos. PC-3 through
PC-10), the Permittee shall comply with the notification and recordkeeping requirements: dates of
construction, anticipated startup and actual startup; performance test data; and excess emissions
reports. The VE shall not be greater than 10%, except for crushers not greater than 15%;Permittee
shall observe the individual sources monthly for normal vs abnormal VE. Permittee shall submit
semiannual summary rpts to DAQ.
APPEARED IN COMPLIANCE — Sources PC-4, 6, 8 & 9, have not been installed; therefore
NSPS notifications have not been submitted. All notifications have been submitted for sources PC-
3, 5, 7, & 10. These sources were not operating during the inspection. Monthly observation
records were complete, indicating "normal," where normal is defined by the facility as <10%
opacity. These sources are grouped in the logbook, but VE observations are made at the individual
sources. Mr. Wallace stated that he has been to smoke school and now knows what 10% opacity
looks like. He also stated that he trained Mr. Meggs and that Mr. Meggs knows what normal looks
like based on his guidance. I again stressed to him that unless a person making the observation has
been to smoke school, then he/she has not been calibrated to know what 10% opacity is. I
encouraged him to either send Mr. Meggs to smoke school so that he could calibrate his eye to the
standards or change the determination of normal to something more descriptive and not based on a
standard that the reader has not been trained on. Semiannual reports have been received on time
and appear complete and valid.
F. 15A NCAC 2D .0524 NEW SOURCE PERFORMANCE STANDARDS SUBPART 000 —
There are two clay grinding operations including: plant scalp screens, finish screens, hammer mill,
storage bins, feeders and conveyors (ID Nos. CG-2 through CG-8 and CG-10 through CG-28); and
scalp screens, finish screens, hammer mill, storage bins, feeders and conveyors (ID Nos. CG-30
through CG-55). The non-stack VE shall not be greater than 10%, except for crushers not greater
than 15%. Permittee shall monthly observe building openings for any VE or source stacks for
normal vs abnormal VE. Permittee shall submit semiannual summary reports to DAQ.
APPEARED IN COMPLIANCE — The facility has chosen to observe the building openings
monthly for any VE. There are two openings to each half of the grinding building (the building has
a dividing wall down the center and two separate clay grinding operations reside in same building).
One conveyor in the grinding operation is in separate building (milling bldg) from the rest of the
subject sources which require VE observations. Observations are made at both openings, for each
side of the grinding building, and the mill building, monthly. The monthly observation records all
indicated "normal," which is then defined by the facilityas "No Visible Emissions." Sources CG-
44 thru CG-55 were operating during the inspection and zero (0) visible emissions were observed
from the building openings. Semiannual reports have been received on time and appear complete
and valid.
G. 15A NCAC 2D .0524 NEW SOURCE PERFORMANCE STANDARDS SUBPART 000 -
For the loam/sawdust preparation area, loam screen, loam crusher, storage bunker, sawdust screen,
and conveyors (ID Nos. LS-2 through LS-12), non-stack VE shall not be greater than 10% except
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for crushers not greater than 15%; Permittee shall observe building openings monthl for an VE.
S SY �
Permittee shall submit semiannual reports to DAQ.
APPEARED IN COMPLIANCE — The facility has chosen to observe the building openings
monthly for any VE. There are two openings, one to each half of the building. Observations are
made at both openings of the building, monthly. The monthly observation records all indicated
"normal," which is then defined by the facility as "No Visible Emissions." The sawdust screen,
bunker and several conveyors (LS-2, LS-8 thru LS-12) were operating during the inspection and
zero (0) visible emissions were observed from the building openings. Semiannual reports have
been received on time and appear complete and valid.
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H. 15A NCAC 2D .0524 NEW SOURCE PERFORMANCE STANDARDS SUBPART Kb—The
Permittee shall maintain records showing the dimension and capacity of storage vessels.
APPEARED IN COMPLIANCE— Tanks T-1 thm T-4 currently listed as subject to this rule all
contain petroleum products such as fuel oils for off road use, and Tank T-5 contains an additive that
is, according to Mr. Wallace, a derivative of pine sap used as a binding agent. These tanks do not
appear to be subject to NSPS Kb because they contain a substance with a vapor pressure way less
that the triggering requirement in the NSPS. It appears that NSPS Subpart Kb has been applied in
error to vessels T-1 thru T-5.
I. 15A NCAC 2D .1109 112j CASE-BY-CASE MACT (Brick) — The compliance date is
4 September 2016. Must meet a filterable PM limit of 0.17 lb/ton total from the kilns, and an HCL-
equivalent (HCL,) emission rate of 9.455 lbs/hr total from both kilns. Source test required within
180 days after compliance date. Must maintain records of production, inspection/maintenance, and
visible emission observations. NOCS due within 60 days of source test. Semi-annual summary
reporting.
APPEARED IN COMPLIANCE—The facility started the DLAs on K-2 in August 2016, prior to
the 4 September 2016 compliance date. They were conducting a source test for PM and HCL, on
13 September 2016, at the time of inspection. The records of production, I&M and VE
observations appeared complete and valid. First semi-annual report will be due 30 January 2017
for 4 September thru 31 December 2016. The facility submitted a minor modification application
containing proposed testing conditions associated with running the DLA and the facility appeared
to be complying with their proposed conditions. They also proposed conditions for monitoring and
recordkeeping associated with running the DLAs, some of which the facility had not yet
implemented at the time of inspection. I advised Mr. Wallace to start conducting the monitoring
and recordkeeping proposed immediately to ensure compliance with the case-by-case MACT both
as it is currently permitted and as they have proposed to change.
J• 15A NCAC 2D .1806 CONTROL AND PROHIBITION OF ODOROUS EMISSIONS — The
Permittee shall prevent odorous emissions from the facility from causing or contributing to
objectionable odors beyond the facility's boundary.
APPEARED IN COMPLIANCE —No odor, associated with this facility, was noticed when
entering or exiting the property. DAQ has not received any complaints since the'previous
inspection. Mr.Wallace stated that the facility has not received any odor complaints.
K. 15A NCAC 2D .1100 TOXIC AIR POLLUTION EMISSION LIMITATIONS AND
REPORTING REQUIREMENT — According to the air toxic compliance demonstration, TAP
emissions will not exceed the established emission limits if they are controlled by limiting the
amount of clay and additives processed in each of the kilns, K-1 and K-2, to 58,000 lbs/hour (29
TPH). Quarterly summary reporting to DAQ.

APPEARED IN COMPLIANCE — Triangle is currently operating K-2 at approx. 60% capacity.
The highest hourly rate for 2016 has been 20.56 tph,below the permit limit. Quarterly reports have
been received on time and appear complete and valid.
L. 15A NCAC 2Q .0711 PERMIT REQUIREMENTS FOR TOXIC AIR POLLUTANTS —The
Permittee shall operate the facility in such a way that any listed TAP emissions from the facility do
not exceed TPERs.
APPEARED IN COMPLIANCE—Based on the current and previous 12 months' operating rates,
Triangle Brick TAP emissions are below the listed TPERs.
M. 15A NCAC 2Q .0317 AVOIDANCE CONDITION FOR 15A NCAC 2D .0530 PREVENTION
OF SIGNIFICANT DETERIORATION—The sulfur dioxide emissions from each kiln shall be
less than 250 tons per 12-month period. For K-1 production is limited to 58,000 lbs/hour each and
the amount of No. 6 fuel oil, with 2.1% sulfur, burned is limited to 920,000 gallons per 12-month
period. K-1 has quarterly summary reporting of SO2 emissions and fuel combustion quantities, K-
2 has same semi-annual reporting.
APPEARED IN COMPLIANCE— The facility bums NG with low sulfur No. 2 fuel oil as back
up only during NG curtailment. The facility has not burned any fuel oil thus far in 2016. SO2
emissions thru June 2016 are approximately 31.44 tons, far below the limit. The highest hourly
production rate for CY 2016 has been 20.56 tons/hr. Quarterly reports have been received on time
and appear complete and valid.
N. PERMIT GENERAL CONDITION LA and LB — REPORTING REQUIREMENTS FOR
EXCESS EMISSIONS AND PERMIT DEVIATIONS: The facility is required to report excess
emission events and malfunctions that last more than 4 hours per the requirements of 15A NCAC
2D .0535.
APPEARED IN COMPLIANCE — Mr. Wallace stated that the facility has had no excess
emission/malfunction events and therefore no notification has been required.
O. PERMIT GENERAL CONDITION P - COMPLIANCE CERTIFICATION
REQUIREMENT: The facility is required to submit an Annual Compliance Certification(ACC)
report postmarked before March 1 of each year, stating compliance with all permit conditions or
noting any deviations during the previous calendar year.
APPEARED IN COMPLIANCE—The latest ACC report was received on O1/28/16 and appeared
complete and valid.
P. GENERAL CONDITION X—ANNUAL EMISSION INVENTORY REQUIREMENTS—The
permittee shall submit an Annual Emission Inventory postmarked on or before June 30' of each
year.
APPEARED IN COMPLIANCE — The facility's 2015 AQEI was received on 06/23/2016 and
appeared to be complete and accurate.
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Q. PERMIT GENERAL CONDITION MM—FUGITIVE DUST CONTROL REQUIREMENT:
The Permittee shall not cause of allow fugitive dust emissions to cause or contribute to substantive
complaints or excess visible emissions beyond the property boundary.
APPEARED IN COMPLIANCE — Mr. Wallace stated that no dust complaints had been received
by the facility, and FRO has not received any dust complaints. There did not appear to be any
issues with fugitive dust from our observations on site.

7. NON-COMPLIANCE HISTORY SINCE 2010:
Nothing negative in Triangle Brick's compliance history since 2010.
8. 112r STATUS:
The facility does not store or process any of the listed chemicals in amounts that exceed the threshold
quantities. Therefore,they are not required to maintain a written Risk Management Plan(RMP).
9. CONCLUSIONS AND RECOMMENDATIONS:
Based on the observations made during the 13 September 2016 compliance inspection, Triangle Brick
Co-Wadesboro appeared to be in compliance with the requirements in their current air permit.
Pink Sheet Issues:
-Recommend speaking with the dozer operator in the mine during the next inspection to determine how
often the pump is moved.
-Bring forward existing pink sheet comments.
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/hsc