AQ_F_0400043_20150721_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY Triangle Brick Cc -Wadesboro
NC Facility ID 0400043
Inspection Report County/FIPS: Anson/007
Date: 07/22/2015
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)None
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 07/21/2015
Inspector's Name Heather Carter
Inspector's Signature. �� Operating Status Operating
JJCC���� Compliance Code Compliance-inspection
Date of Signature:. _ / Action Code FCE
5 On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
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
20l'l. 11.36 17.28 7.26 3.27 33.24 9.63 2995.90
*Highest HAP Emitted(in pounds)
Five Year Violation History:
None
Performed Stack Tests since last FCE:
None
1. MACT/GACT APPLICABILITY:
Triangle Brick Co — Wadesboro facility is subject to the 112j Case-by-Case MACT (Brick). They have
no boilers on site, and therefore are not subject to the Boiler MACT(Subpart DDDDD). They have one
diesel-fired internal combustion engine on a pump in the mine. It is classified as a non-road engine, as it
is moved to a new location in the mine at least once a year, and is therefore not subject to the
Reciprocating Internal Combustion Engine(RICE)MACT(Subpart ZZZZ).

2. DIRECTIONS TO SITE:
Triangle Brick is located on US52 in Wadesboro, NC, Anson County. From FRO, take US401 south to
US74; turn right onto US74 West. Follow US74 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).
3. SAFETY:
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.
4. 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 ajaw
crusher to reduce the size and then continues on to the storage shelter. 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 kiln. The firing takes more than two days. After firing the brick are
packaged into skid loads (by a very cool robot) and stored prior to purchase and shipment.
5. INSPECTION SUMMARY:
On 21 July 2015, Josh Harris and I, Heather Carter, both from FRO DAQ, met with Mr. Nathan Wallace,
the new Plant Manager, to conduct the annual compliance inspection. We toured the facility starting at
the storage shed through the brick-making process and performed a records review. Triangle is currently
operating at—75% capacity of Kiln #2; Kiln #1 is not operating at this time. The dry lime absorbers are
still on the permit (with no requirements for operation, I&M, recordkeeping or reporting) and still
connected to the kilns exhaust systems but have not been operated since issuance of their current permit
in September 2013. Records appeared complete except that they need to start recording the time of each
observation for the sand dryer, all other sources observed had time and dates recorded. The side of the
building, facing Kiln 2, housing the hammer mill has deep clay colored staining underneath the louvered
vents, indicative that some PM is making it outside the building. However, the hammer mill, conveyors
and screens were operating during the inspection and we observed zero (0) visible emissions from the
building vents and doors. The other side of this building, facing the road, did not have this staining but it
also appeared that the louvered vents were not open.
We discussed with Mr. Wallace and Mr. Ricky Merritt, Director of Engineering, who was also on site
during the inspection, the Case-by-Case Brick MACT condition in their permit. I reminded them of the
compliance date and also advised that if they have any question about whether they can comply with the
PM and HCL equivalent limits they should consider testing in advance of the compliance date to allow
time for corrective actions.

6. PERMITTED EMISSION SOURCES:
Emission Emission Source Control Control Device
Source Description '' Device Description
II)No. ID No.
Two Brick Tunnel Kilns
K-1 One natural gas/No.2 fuel oil/No. 6 fuel CD-Kl 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 er 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 w/0% VE 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 Operating 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 op/2 Not installed
PC-3 and PC-4 Two scalp screens N/A N/A
NSPS 000
3 Not Op/4 Not installed
PC-5 and PC-6 Two jaw crushers N/A N/A
NSPS 000
5 Not op/6 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
O eratin w/0% VE
$mission. - Emission Source Control Control Device
E'Source`' Description Device Description
IDtNo: ID No.
Two Secondary Clay Grinding Plants and Associated Conveyances
CG-1 One clay feeder N/A N/A
O 0% VE at bldg. opening
CG-2 One conveyor belt to scalping screen N/A N/A
NSPS 000
O 0% VE at bid . o enin
CG-3 One scalping screen N/A N/A
NSPS 000
Op 0% VE at brdg. opening

CG-4 One return conveyor belt for oversize from N/A N/A
NSPS 000 screens
OP 0% VE at bldg. opening
CG-5 One conveyor belt to hammer mill N/A N/A
NSPS 000
Op 0% VE at bld . opening
CG-6 One hammer mill N/A N/A
NSPS 000
OP 0% VE at bldg. opening
CG-7 One conveyor belt under hammer mill N/A N/A
NSPS 000
O 0% VE at bldg. opening
CG-8 One conveyor belt to finish screens N/A N/A
NSPS 000
O 0% VE at bldg. opening
CG-10 through CG-13 Four finish screens N/A N/A
NSPS 000
Op 0% VE at bldg. o enin
CG-14 One fines conveyor belt under screens N/A N/A
NSPS 000
Op 0% VE at bldg. opening
CG-15 One conveyor belt to storage bins N/A N/A
NSPS 000
O 0% VE at bld . o enin
CG-16 One conveyor belt over storage bins N/A N/A
NSPS 000
Op 0% VE at bldg. o enin
CG-17 through CG-21 Five storage bins N/A N/A
NSPS 000
O 0% VE at bldg. o enin
CG-22 through CG-26 Five feeders under storage bins N/A N/A
NSPS 000
O 0% VE at bldg. opening
CG-27 One conveyor in front of storage bins N/A N/A
NSPS 000
Op 0% VE at bldg. opening
CG-28 One conveyor to pug mill N/A N/A
NSPS 000
Op 0% VE at bldg. o enin
CG-29 One clay feeder N/A N/A
OP 0% VE at bldg. opening
CG-30 One conveyor belt to scalping screen N/A N/A
NSPS 000
OP 0% VE at bldg. o enin
CG-31 One scalping screen N/A N/A
NSPS 000
O 0% VE at bld . o enin
CG-32 One return conveyor belt for oversize from N/A N/A
NSPS 000 screen
Op 0% VE at bld . opening
CG-33 One conveyor belt to hammer mill N/A N/A
NSPS 000
O 0% VE at bld . o enin
CG-34 One hammer mill N/A N/A
NSPS 000

Op 0% VE at bldg. opening
CG-35 One conveyor belt under hammer mill N/A N/A
NSPS 000
Op 0% VE at bldg, opening
CG-36 One conveyor belt to finish screens N/A N/A
NSPS 000
On 0% VE at bld . opening
CG-37 through CG-40 Four finish screens N/A N/A
NSPS 000
Op 0% VE at bldg. opening
CG-41 One fines conveyor belt under screens N/A N/A
NSPS 000
Op 0% VE at bldg. opening
CG-42 One conveyor belt to storage bins N/A N/A
NSPS 000
on 0% VE at b1d . opening
CG-43 One conveyor belt over storage bins N/A N/A
NSPS 000
O 0% VE at bldg, opening
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
O 0% VE at bldg, opening
CG-54 One conveyor in front of storage bins N/A N/A
NSPS 000
On 0% VE at bldg. opening
CG-55 One conveyor to pug mill N/A N/A
NSPS 000
Op 0% VE at bldg, 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
O 0% VE at bldg, opening
LS-4 One loam crusher N/A N/A
NSPS 000
Op 0% VE at bldg. opening
LS-5 One oversize return conveyor from LS-3 N/A N/A
NSPS 000
Op 0% VE at bldg, opening
LS-6 One oversize return chute N/A N/A
NSPS 000
O 0% VE at bld . opening
LS-7 One fines conveyor belt under LS-3 to N/A N/A
NSPS 000 bunker belt conveyor
Op 0% VE at b[dg. opening

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% VEat Wk. opening
LS-11 One conveyor to storage bins N/A N/A
NSPS 000
Op 0% VE at h1dg. opening
LS-12 One oversize conveyor from sawdust screen N/A N/A
NSPS 000
Op 0% VE at hid . opening
=Emission Emission Source Control Control Device
Source Description Device Description
IIJ No.. ID No.
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
T-4 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
7. PERMIT EXEMPT EMISSION SOURCES:
� op �olt ce 7 ,:rm sswn,Source Das�rapnon
IS-Tank 3,000 gallon aboveground gasoline storage tank
8. 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
at a production rate of 29 tons/hour(4.1 x P° 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
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; however 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 Ibs/hr at
29 tons/hr production. The facility is currently operating at approximately 21 tph. During the
inspection, I reviewed I&M records documenting internal and external inspections that were
conducted semi-annually(K-2: Jan 27 &July 22, 2014 and Jan 15,2015). Semiannual reports have
been received on time and appear complete and valid.

Sulfur dioxide
B. 15A NCAC 2D .0516 SULFUR DIOXIDE CONTROL REQUIREMENT —
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 COMPLLANCE—Kiln#2 is currently operating on NG. Since January 2010 the
facility has only used 42 fuel oil as back up fuel during NG curtailment (Jan & Nov 2014; Feb
2015). 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.
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, Kiln #2 was operating with 0% VE
from the kiln stack. Kiln#1 ceased operation in Dec 2013. I reviewed the log that documents VE
observations as normal each month. 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 any 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 then defined as "No Visible Emissions."
The unit was not operating during the inspection. The records appeared complete and valid except
that the time,of the observations was missing. I advised Mr. Wallace to start including the time
these observations are made. I also reviewed records of semi-annual inspections on the dryer (Jan
20 & July 2, 2014 and Jan 15, 2015), 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. Monthly observation records were complete, indicating "normal," where normal is
<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. The crushing operations were not
operating during the inspection. 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 as "No Visible Emissions." 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
for crushers not greater than 15%; Permittee shall observe building openings monthly for any VE.
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 to each half of the building (the building has a
dividing wall down the center and two separate clay grinding operations reside in same building).
Observations are made at both openings, for each side of the building, monthly. The monthly
observation records all indicated "normal," which is then defined as "No Visible Emissions."
Semiannual reports have been received on time and appear complete and valid.
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 thru 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 Sept 4,
2016. Must meet a filterable PM limit of 0.17 lb/ton total from both kilns, and an HCL-equivalent
emission rate of 9.455 Ibs/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 compliance date has not yet passed; therefore no
requirements are triggered at this time.
J. 15A NCAC 2D .1806 CONTROL AND PROHIBITION OF ODOROUS EMISSIONS — The
Permittee shall not allow objectionable odors to extend 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.
K. 15A NCAC 2D .1100 TOXIC AIR POLLUTION EMISSION LIMITATIONS AND
REPORTING REQUIREMENT — TAP emissions shall be 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 Kiln #2 at approx. 75%
capacity. The highest hourly rate so far in CY 2015 is 20.6 tph. 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 emissions reported in the 2014 EI, the current and
last 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. The kiln production is limited to 58,000 Ibs/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. Quarterly summary reporting to DAQ.
APPEARED IN COMPLIANCE— The facility burns NG with low sulfur No. 2 fuel oil as back
up. No. 2 fuel oil was burned in Nov 2014 and Feb 2015 during NG curtailment. S02 emissions
thru June 2015 are approximately 33 tons, far below the limit. Highest hourly production rate so
far in CY 2015 is 20.6 tph. Quarterly reports have been received on time and appear complete and
valid.
N. ANNUAL COMPLIANCE CERTIFICATION DUE— Submit the report by March I"every year
for the preceding CY.
APPEARED IN COMPLIANCE - Last ACC received on 28 January 2015 for CY 2014. Report
appeared to be valid and complete.
9. NON-COMPLIANCE HISTORY SINCE 2010:
Nothing negative in Triangle Brick's compliance history since 2010.
10. 112r STATUS:
Based on visual observations and past personnel interviews, this facility is subject only to the general
provisions of the 112r regulation.
i

11. CONCLUSIONS AND RECOMMENDATIONS:
Based on the observations made during the 21 July 2015 compliance inspection, Triangle Brick Co-
Wadesboro appeared to be in compliance with the requirements in their current air permit.
Pink Sheet Issues:
1) Tanks T-1 thru T-5 do not appear to be subject to NSPS Kb based on vapor pressures, remove
requirements from permit and, if appropriate,relocate tanks to insignificant list.
/hsc