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HomeMy WebLinkAboutAQ_F_1900009_20150908_ST_ProtRvw (4) NCDENR North Carolina Department of Environment and Natural Resources Pat McCrory Donald R. van der Vaart Governor Secretary September 8,2015 Warren Paschal Manager of Environmental Compliance General Shale Brick, Inc. -Moncure Facility 300 Brick Plant Road Moncure,NC 27559 Subject: Protocol for Filterable Particulate Matter, Hydrogen Chloride and Hydrogen Fluoride Emissions Testing on Brick Tunnel Kiln ES-K4K General Shale Brick,Inc.—Moncure Facility Moncure, Chatham County,North Carolina Air Permit No. 04384T18,Facility ID 19/00009 Proposed Test Date: September 24, 2015 Tracking No. 2015-165ST Dear Mr. Paschal: The protocol submittal form(PSF)prepared by Environmental Source Samplers,Inc. (ESS)has been reviewed for filterable particulate matter(PM),hydrogen chloride(HC1) and hydrogen fluoride(HF) emissions testing and deemed acceptable. The test is being conducted to demonstrate compliance with Case-by-Case MACT. The emissions source being tested is a natural gas/propane/coal-fired brick tunnel kiln ES-K4K(25.9 million Btu per hour heat input)and associated dry limestone adsorber(DLA)CD-K4DLA and the three associated natural gas/propane-fired brick dryers ES-K4D1, ES-K4D2, and ES-K4D3. 15A NCAC 2D .1109: Case-by-Case MACT applies. Permit Condition 2.1-A.4.b stipulates the Case-by- Case MACT limits for the proposed pollutants. 15A NCAC 2D .0515 Particulate Emissions From Miscellaneous Industrial Process also apply. The sources,pollutants, and methods are tabulated below: Emus an Source 1Cb Tos, Pcallutant EPA Brick Kiln ES-K4K Volumetric Flow Rates M1, 2, &4 Oxygen,Carbon Dioxide M3A Filterable PM M5 HCl/HF M26A The proposed test methods are acceptable for the specified pollutants. Approval of the protocol does not exempt the tester in any way from the minimum requirements of the applicable methods. Since no deviations from the applicable testing methodology were addressed in the test protocol,the testing should be conducted in strict accordance with the requirements of EPA Methods 1,2, 3A,4, 5, and 26A. 1641 Mail Service Center,Raleigh,North Carolina 27699-1641 Phone:919-707-84001 Internet:www.ncdenr.gov An Equal Opportunity l Affirmative Action Employer—Made in part by recycled paper Warren Paschal September 8, 2015 Page 2 of 2 The permitted maximum process rate is 20.55 tons per hour(tph)heat input.The maximum normal process rate for kiln ES-K4K is> 18.50 tph fired brick production rate. The target process rate for testing is> 18.50 tph fired brick production rate. Permit Condition 2.1-A.4.f states that the permittee shall maintain a pressure drop across the DLA CD- K4DLA at the large tunnel kilns. ESS has stated in the PSF that the pressure drop will be recorded during the testing. Note that audit sample analysis is required for the Method 26A proposed. ESS has submitted an audit sample order request and 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.gov,lttn/emciemail.html#audit. Any modifications to the applicable test methods remain subject to approval by the Division of Air Quality(DAQ). Please insure all relevant process/operating data is included and summarized in the test report. If you have any questions,please feel free to contact me at David.B.HughesCamcdenr.gov or(919) 707-8411. Sinc 'y, 4 'Gt� - David B. Hughes, Enviro ental Engineer Division of Air Quality,NCDElv'R Cc: Melanie Bethea, Environmental Source Samplers, Inc. Patrick Butler/Stanley Williams—Raleigh Regional Office Central Files—Chatham County IBEAM Documents— 1900009 (09/24/15)