AQ_F_0400043_20160428_CMPL_Fac-Ltr

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C A Triangle Brick
6523 NC Highway 55
Durham, NC 27713
Durham:[phone].
April 28, 2016 Raleigh: [phone]
Toll Free:800-672-8547
Fax:[phone]
North Carolina Department of Environmental Quality
Fayetteville Regional Office RE Cr E!V E D
Division of Air Quality
225 Green Street-Suite 714 : MAY 0 5 2�i6
Fayetteville,North Carolina 28301-5043
I,I . r � .
Attention: Steven Vozzo FRG _-.,
Regional Air Quality Supervisor
Re: Request for Approval 1120) Equivalent Initial Compliance Demonstration
Triangle Brick Company
Wadesboro Brick Manufacturing Plant
Dear Mr.Vozzo:
This letter is a request for previously conducted performance tests at Triangle Brick Company's
brick manufacturing plant in Wadesboro, NC to be approved to satisfy the current permit
requirement for an initial compliance test.
Triangle Brick's Wadesboro "plant complies with the Case-by-Case MACT for Brick
Manufacturers, as described in 15A NCAC 2D.1109: CAA §1120). Wadesboro's Title V Permit
08179T08 contains site-specific 1120) provisions' in Section 2.1.A.4. Wadesboro's initial
compliance date for its 1120) permit provisions is September 4, 2016. We have assumed that the
requirements under the Case-by-Case MACT will be effective until 8 years after the effective
date of the applicable federally promulgated MACT (October 26, 2023).
Wadesboro's 1120) permit provisions require initial compliance testing for Particulate Matter
(PM), Hydrogen Fluoride (HF), and Hydrogen Chloride (HCl) within 180 days of September 4,
2016, unless NCDAQ-SSCB (Stationary Source Compliance Branch) approves a`previously
conducted performance test as an equivalent compliance demonstration.
Wadesboro's 1120)permit provisions for initial compliance testing are:
• PM testing is required for the tunnel kilns, K-1 and K-2, and must be Method 5 in 40
CFR 60,Appendix A.
• HF'and HCl testing is required for the tunnel kilns, K-1 and K-2, and must be either:
o Method 26 or 26A in 40 CFR 60, Appendix A.Method 26A may only be used
when no acid PM is present,
o Method 320 in in 40 CFR 63, Appendix A.
• Testing may not be conducted during periods of startup, shutdown, or malfunction.

Triangle Brick performed stack testing on K-2 in March 2005 and on K-1 in March 2006. The
1 testing was performed by Trigon Engineering Consultants, Inc. Copies of each report are
included as attachments to this letter.
Both PM tests used Method 5, and both HF and HCl tests used Method 26A, as outlined in
Section 3.2 of both reports. As stated in Section 1.2 of both reports, all tests were performed
during normal production and operating conditions. Section 2.1 in both reports states the
jproduction rates.
Triangle Brick believes that these tests satisfy the requirements of Wadesboro's 1220) permit
provisions for initial compliance testing and is requesting that these tests be approved as
equivalent compliance demonstrations.
Please do not hesitate to contact me at [phone] or our consultant, Rachel Kazanski at
[phone] if you have questions or if you need additional information to complete your
review.
Sincerely,
TRIANGLE BRICK COMPANY
/ � �) /� t-A
Howard P.Brown,Jr.
Executive Vice President and Chief Operating Officer
cc: Ricky Merritt—Triangle Brick Company