AQ_F_0400043_20140225_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: 03/05/2014
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
NAILS: 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
MALT PartJJJJJ
Nathan Wallace Howard Brown,Jr Howard Brown,Jr
NSPS: Subpart
Subpart 000, Subpart
UUU
Plant Manager VP of Production& VP of Production&
[phone] Engineering Engineering
[phone] [phone]
Compliance Data
Comments:
Inspection Date 02/25/2014
Inspector's Name Heather Carter
Inspector's Signature: � Operating Status Operating
C2C� Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: 3/� // On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP SO2 NOX VOC CO PM10 *HAP
2012 13.74 20.92 8.79 3.96 40.23 11.66 3626.00
2011 11.36 17.28 7.26 3.27 33.24 9.63 2995.90
2010 11.18 17.78 7.36 3.21 32.73 9.48 2896.17
* Highest HAP Emitted(in ounds)
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 thin 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 bar 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 a jaw
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 25 February 2014, Greg Reeves, 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. Mr. Ricky
Merritt, Director of Engineering, joined us for the records review. Triangle is currently operating at
—80% 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.
While reviewing the records for VE observations and I&M, we discovered that the facility had been
observing the sand dryer daily(as required) at about the same time, but that it was not always operating at
that time. The observer had been recording OFF to indicate the unit was not running during the
observation. We discussed whether the unit usually or normally did run sometime during the day and
learned that the unit does run almost every day, if not but for a few hours. I discussed with Mr. Wallace
and Mr. Merritt the intent of the requirement being to observe the unit for VE while it is running daily,
and to only record OFF if the unit did not run that day. I confirmed this procedure with Steven Vozzo,
RAQS, upon returning to the office.
The new permit still lists the AST's containing diesel fire] as subject to NSPS Kb. My review of these
sources shows that they are not subject to NSPS Kb because they contain a substance with a vapor
pressure way less that the triggering requirement in the NSPS. Additionally, the Additive in T-5 is a pine
sap'derivative and thus would also not be subject to NSPS Kb.

6. PERMITTED EMISSION SOURCES:
Emron `" Emission Source Control Control Device
Source y Description Device Description
ID No.
Two Brick Tunnel Kilns
K-1 One natural gas/No.2 fuel oil/No. 6 fuel oil- CD-Kl Dry Limestone
2D.1109 Case-by-Case fired Brick Tunnel Kiln(29.0 tons per hour Adsorber(DLA)
MACT material output rate,42.8 million Btu per hour
Not Operating heat input rate)
K-2* One natural gas/No.2 fuel oil/No. 6 fuel oil- CD-K2 Dry Limestone
2D .1109 Case-by-Case fired Brick Tunnel Kiln(29.0 tons per hour Adsorber(DLA)
MACT material output rate,42.8 million Btu per hour
Op on NG w/0% heat input rate)
VE
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 Opera 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 O I4 Not installer!
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 Operating
PC-9 One cross-over conveyor N/A N/A
NSPS 000
Not Operating
PC-10 One shuttle conveyor N/A N/A
NSPS 000
Not Operating
Fmtssion aP`r ar Emission Source) Control Control'Device
Source Description Device Description'
x t; ]ED No.
Two Secondary Clay Grinding Plants and Associated Conveyances
CG-1 One clay feeder N/A N/A
Not Operating
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 Operating
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 O eratin
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
NSPS 000
Not O era in
CG-32 One return conveyor belt for oversize from N/A N/A
NSPS 000 screen
Not Operating
CG-33 One conveyor belt to hanuner 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 O era tin
CG-36 One conveyor belt to finish screens N/A N/A
NSPS 000
Not Operating
p
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
Not Operating
CG-49 through CG-53 Five feeders under storage bins N/A N/A
NSPS 000
Not Operating
CG-54 One conveyor in front of storage bins N/A N/A
NSPS 000
Not Operating
CG-55 One conveyor to pug mill N/A N/A
NSPS 000
Not Operating
Loam/ Sawdust Preparation Operation and Associated Conveyances
LS-1 Loam/sawdust feeder N/A N/A
Not Operating
LS-2 One conveyor from loam/sawdust feeder to N/A N/A
NSPS 000 finish screens
Not Operating
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 bunker N/A N/A
NSPS 000 belt conveyor
Not Operating
LS-8 One belt conveyor to bunker N/A N/A
NSPS 000
Not Operating
LS-9 One storage bunker N/A N/A
NSPS 000
Not Operating
LS-10 One sawdust screen N/A N/A
NSPS 000
Not Operating
LS-11 One conveyor to storage bins N/A N/A
NSPS 000
Not Operating
LS-12 One oversize conveyor from sawdust screen N/A N/A
NSPS 000
Not Operating
Emission I Emission Source Control Control Device
Source '4. .; Description Device Description
IDNo.
Above Ground Storage Tanks
T-1 One 24,000 gallon above ground No. 6 fuel oil N/A N/A
NSPS Kb storage tank
T-2 and T-3 Two 24,000 gallon above ground No. 2 fuel oil N/A N/A
NSPS Kb 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"A" N/A N/A
NSPS Kb storage tank
7. PERMIT EXEMPT EMISSION SOURCES:
}�xmss 6 S
Emisso Decnpe don-M,
IS-Tank 3,000 gallon above ground 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 COMPLLANCE—Facility operates on NG with fuel oil as backup. The result of
the 14 March 2006 source test for PM(filterable only)was an emission rate of 2.03 Ibs/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 lbs/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-1: Jan & July 2013; K-2: Jan 2014). 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 cons when using No. 6 fuel oil.
APPEARED IN COMPLIANCE—Kiln 92 is currently operating on NG. Since January 2010 the
facility has only used #2 fuel oil on two days in amt of—665 gallons. Since 2007, the facility has
only received one shipment of No. 6 fuel oil (S= 1.36%) and has not combusted any of it 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. 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 then defined as "No Visible Emissions."
The unit was not operating during the inspection. I also reviewed records of semi-annual
inspections on the dryer (Jan & July 2013 and Jan 2014), 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 employee Trevor Galler was now making the VE
observations. Mr. Reeves and I questioned how he knows what<10% opacity looks like if he has
never been to visible emission evaluation school/training (smoke school). Mr. Wallace stated that
he has trained Mr. Galler and that he knows what normal looks like based on his guidance. We
_ suggested that it would be a good idea to send Mr. Galler to smoke school once to ensure he knows
what 10% opacity looks like. 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.
1. 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 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 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
Pennittee 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. Mr. Wallace stated that they have not received any complaints
from citizens,nor has DAQ received any complaints.
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 92 at just over 80%
capacity. The highest hourly rate during the last 12 months was 21.16 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 2012 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 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. Quarterly summary reporting to DAQ.
APPEARED IN COMPLIANCE —No. 2 fuel oil has only been combusted on two days (Jan 8 &
9,2014; approx. 665 gallons) since January 2010. S02 emissions for CY 2013 were approximately
30 tons, far below the limit. Highest hourly production rate in CY 2012 was 21.16 tph. Quarterly
reports have been received on time and appear complete and valid.
9. 112r STATUS:
Based on visual observations and past personnel interviews, this facility is subject only to the general
provisions of the 112r regulation.
10. CONCLUSIONS AND RECOMMENDATIONS:
Based on the observations made during the 25 February 2014 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