AQ_F_0400043_20130129_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY Triangle Brick Co-Wadesboro
NC Facility ID 0400043
Inspection Report County/FIPS: Anson/007
Date: 01/31/2013
Facility Data Compliance Data
Triangle Brick Co-Wadesboro Inspection Date 01/29/2013
US Hwy 52 Inspector's Name Heather Hawkins
Wadesboro,NC 28170 Operating Status Operating
Lat: 35d 1.1463m Long: 80d 5.1235m Compliance Code Compliance-inspection
SIC: 3251 /Brick And Structural Clay Tile Action Code FCE
NAICS: 327121 /Brick and Structural Clay Tile Manufacturing On-Site Inspection Result Compliance
Contact Data Permit Data
Facility Contact Authorized Contact Technical Contact Permit 08179/T07
Paul Maxwell Howard Brown,Jr Howard Brown,Jr Issued 12/I1/2007
Plant Manager VP of Production& VP of Production& Expires 5/31/2012
[phone] Engineering Engineering Classification Title V
[phone] [phone] Permit Status Active
Inspector's Signature: ��\�'��✓ � Comments:
Date of Signature: f 14
MACT/GACT APPLICABILITY:
Triangle Brick Co — Wadesboro facility was subject to the Brick MACT (Subpart JJJJJ), until it was
vacated. EPA plans to promulgate a new Brick MACT around August 2013. The facility has submitted
to the DAQ a 112j,MACT Hammer, application using the Health Based Compliance Alternative analysis.
They may avoid being subject to the new Brick MACT, when it is promulgated, for a maximum of 8 yrs
from their permit issuance. 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).
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 US52 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(DLA stack, openings in bldg with grinders).
SAFETY:
Safety glasses and shoes required; helmet 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.
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 sawdust loam and 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, 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.
INSPECTION SUMMARY:
On 29 January 2013, Robert Hayden, Mike Thomas, and I, all from FRO DAQ, met with Paul Maxwell,
Plant Manager, to conduct the annual compliance inspection. Mr. Nathan Wallace, Kiln Supervisor,
provided and discussed the records. Triangle is currently operating at—30% capacity (one kiln operating
at just above 50%). The housing market slowdown in 2008 drastically reduced the markets for brick,but
they are slowly starting to increase production (12 cars/day in 2012 vs 11 cars/day in 2011). Kiln K-1
was operating during the inspection, and kiln #2 has not operated since 2008. While not currently
required to, Triangle continues to operate the DLA(dry limestone absorber), but there are no monitoring,
record keeping or reporting requirements.
While reviewing the records for VE observations and I&M, we discovered that one conveyor in the
grinding operation is in separate building(milling bldg)from the rest of the subject sources which require
VE observations. Mr. Wallace has not been observing the milling building for VE as he has been for the
grinding building. This is obviously an over-site, and he will begin observing the milling building
opening for VE on the same frequency as the grinding building. The logbook will reflect that he does the
VE observations on the two buildings. We also discussed not modifying the logbook to remove the
records for the DLA until their permit is issued and the requirements are known.
Since their permit is currently in the process of being renewed, we discussed the ASTs containing diesel
fuel. These sources are currently permitted 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. I advised that during permit renewal is the time to address this
issue and have the tanks removed, if the permit writer agrees that the tanks are not subject to the NSPS.
The facility's application for permit renewal is currently in-house at RCO and lumped together with their
112j application. The permit writer anticipates the issuance of the permit including the 112j requirements
by March 2013.
PERMITTED EMISSION SOURCES: *NOTE: Kiln#1 was only source operating during inspection
Emission Emission Source Control Control Device
Source Description Device Description
ID No. ID No.
Two Brick Tunnel Kilns
K-1 One natural gas/No.2 fuel oil/No. 6 fuel oil- CD-K1** Dry Limestone
fired Brick Tunnel Kiln(29.0 tons per hour Adsorber(DLA)
material output rate,42.8 million Btu per hour
heat input rate)
K-2* One natural gas/No.2 fuel oil/No.6 fuel oil- CD-K2* Dry Limestone
fired Brick Tunnel Kiln(29.0 tons per hour Adsorber(DLA)
material output rate,42.8 million Btu per hour
heat input rate)
Rotary Coatings Dryer
SD-1 One natural gas-fired Rotary Coatings Dryer N/A N/A
(8.1 tons of clay per hour material input rate,

0.3 million Btu per hour heat input rate)
NSPS-40 CFR Part 60 Subpart UUU
Primary Crushing Plant and Associated Conveyances
PC-1 and PC-2 Two shale feeders N/A N/A
PC-3 and PC-4 Two scalp screens N/A N/A
NSPS-40 CFR Part 60 Subpart 000
PC-5 and PC-6 Two jaw crushers N/A N/A
NSPS-40 CFR Part 60 Subpart 000
PC-7 One conveyor under PC-3 and PC-5 N/A N/A
NSPS-40 CFR Part 60 Subpart 000
PC-8 One conveyor under PC-4 and PC-6 N/A N/A
NSPS-40 CFR Part 60 Subpart 000
PC-9 One cross-over conveyor N/A N/A
NSPS-40 CFR Part 60 Subpart 000
PC-10 One shuttle conveyor N/A N/A
NSPS-40 CFR Part 60 Subpart 000
Emission Emission Source Control Control Device
Source Description Device Description
ID No. ID No.
Two Secondary Clay Grinding Plants and Associated Conveyances
CG-1 One clay feeder N/A N/A
CG-2 One conveyor belt to scalping screen N/A N/A
NSPS-40 CFR Part 60 Subpart 000
CG-3 One scalping screen N/A N/A
NSPS-40 CFR Part 60 Subpart 000
CG-4 One return conveyor belt for oversize from N/A N/A
screens
NSPS-40 CFR Part 60 Subpart 000
CG-5 One conveyor belt to hammer mill N/A N/A
NSPS-40 CFR Part 60 Subpart 000
CG-6 One hammer mill N/A N/A
NSPS-40 CFR Part 60 Subpart 000
CG-7 One conveyor belt under hammer mill N/A N/A
NSPS-40 CFR Part 60 Subpart 000
CG-8 One conveyor belt to finish screens N/A N/A
NSPS-40 CFR Part 60 Subpart 000
CG-10 through CG-13 Four finish screens N/A N/A
NSPS-40 CFR Part 60 Subpart 000
CG-14 One fines conveyor belt under screens N/A N/A
NSPS-40 CFR Part 60 Subpart 000
CG-15 One conveyor belt to storage bins N/A N/A
NSPS-40 CFR Part 60 Subpart 000
CG-16 One conveyor belt over storage bins N/A N/A
NSPS-40 CFR Part 60 Subpart 000
CG-17 through CG-21 Five storage bins N/A N/A
NSPS-40 CFR Part 60 Subpart 000
CG-22 through CG-26 Five feeders under storage bins N/A N/A
NSPS-40 CFR Part 60 Subpart 000
CG-27 One conveyor in front of storage bins N/A N/A
NSPS-40 CFR Part 60 Subpart 000
CG-28 One conveyor to pug mill N/A N/A

NSPS-40 CFR Part 60 Subpart 000
CG-29* One clay feeder N/A N/A
CG-30* One conveyor belt to scalping screen N/A N/A
NSPS-40 CFR Part 60 Subpart 000
CG-31* One scalping screen N/A N/A
NSPS-40 CFR Part 60 Subpart 000
CG-32* One return conveyor belt for oversize from N/A N/A
screens
NSPS-40 CFR Part 60 Subpart 000
CG-33* One conveyor belt to hammer mill N/A N/A
NSPS-40 CFR Part 60 Subpart 000
CG-34* One hammer mill N/A N/A
NSPS-40 CFR Part 60 Subpart 000
CG-35* One conveyor belt under hammer mill N/A N/A
NSPS-40 CFR Part 60 Subpart 000
CG-36* One conveyor belt to finish screens N/A N/A
NSPS-40 CFR Part 60 Subpart 000
Emission Emission Source Control ` Control Device
Source _ Description Device Description
ID No. ID No.
CG-37 through CG-40* Four finish screens N/A N/A
NSPS-40 CFR Part 60 Subpart 000
CG-41* One fines conveyor belt under screens N/A N/A
NSPS-40 CFR Part 60 Subpart 000
CG-42* One conveyor belt to storage bins N/A N/A
NSPS-40 CFR Part 60 Subpart 000
CG-43* One conveyor belt over storage bins N/A N/A
NSPS-40 CFR Part 60 Subpart 000
CG-44 through CG-48* Five storage bins N/A N/A
NSPS-40 CFR Part 60 Subpart 000
CG-49 through CG-53* Five feeders under storage bins N/A N/A
NSPS-40 CFR Part 60 Subpart 000
CG-54* One conveyor in front of storage bins N/A N/A
NSPS-40 CFR Part 60 Subpart 000
CG-55* One conveyor to pug mill N/A N/A
NSPS-40 CFR Part 60 Subpart 000
Loam/ Sawdust Preparation Operation and Associated Conveyances
LS-1 Loam/sawdust feeder N/A N/A
LS-2 One conveyor from loam/sawdust feeder to N/A N/A
finish screens
NSPS-40 CFR Part 60 Subpart 000
LS-3 One loam screen N/A N/A
NSPS-40 CFR Part 60 Subpart 000
LS-4 One loam crusher N/A N/A
NSPS-40 CFR Part 60 Subpart 000
LS-5 One oversize return conveyor from LS-3 N/A N/A
NSPS-40 CFR Part 60 Subpart 000
LS-6 One oversize return chute N/A N/A
NSPS-40 CFR Part 60 Subpart 000

LS-7 One fines conveyor belt under LS-3 to bunker N/A N/A
belt conveyor
NSPS-40 CFR Part 60 Subpart 000
LS-8 One belt conveyor to bunker N/A N/A
NSPS-40 CFR Part 60 Subpart 000
LS-9 One storage bunker N/A N/A
NSPS-40 CFR Part 60 Subpart 000
LS-10 One sawdust screen N/A N/A
NSPS-40 CFR Part 60 Subpart 000
LS-11 One conveyor to storage bins N/A N/A
NSPS-40 CFR Part 60 Subpart 000
LS-12 One oversize conveyor from sawdust screen N/A N/A
NSPS-40 CFR Part 60 Subpart 000
Emission Emission Source Control Control Device
Source Description Device Description
ID No. ID No.
Above Ground Storage Tanks
T-1 One 24,000 gallon above ground No.6 fuel oil N/A N/A
storage tank
NSPS-40 CFR Part 60 Subpart Kb
T-2 and T-3 Two 24,000 gallon above ground No.2 fuel oil N/A N/A
storage tanks
NSPS-40 CFR Part 60 Subpart Kb
T-4 One 24,000 gallon above ground highway N/A N/A
diesel fuel oil storage tank
NSPS-40 CFR Part 60 Subpart Kb
T-5 One 24,000 gallon above ground Additive"A" N/A N/A
storage tank
NSPS-40 CFR Part 60 Subpart Kb
PERMIT EXEMPT EMISSION SOURCES:
.............__..__..................
Emissiod8ource ID Emission Source Description
No.
IS-Tank 3,000 gallon above ground gasoline storage tank
APPLICABLE AIR QUALITY REGULATIONS:
A. 15A NCAC 2D .0515 PARTIUCLATES 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 0.67). 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 fuel oil as backup. They haven't
used fuel oil since January 2010. 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. The facility is currently
operating at 14.6 tons/hr. During the inspection,I reviewed I&M records documenting internal and
external inspections that were conducted semi-annually. 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—Kiln #1 is currently operating on NG, and last combusted No.
2 fuel oil in Jan 2010. 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#2 has not operated since Dec 2008. 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 #1 was operating and I observed
0% VE from the kiln stack at the DLA. Mr. Maxwell stated that while burning natural gas they
never see any VE from the stack, and if they did there would be a bigger issue with the product
coming out of the kiln and would therefore be quickly investigated and corrected. Kiln #2 has not
operated since Dec 2008. 1 reviewed the log that documents VE observations as normal each week
(Note: this exceeds the requirement for month obs). 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), the Permittee shall comply with the notification and
recordkeeping requirements: dates of construction, anticipated startup and actual startup;
performance test data; excess emissions reports. VE shall not be greater than 10%; Permittee shall
observe source stack 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 semiannual summary
rpts to DAQ.
APPEARED IN COMPLIANCE—All notifications have been completed. 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, 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-2, 4, 6, 8 & 9, have not been installed; therefore
NSPS notifications have not been submitted. All notifications have been submitted for sources PC-
1, 3, 5, 7, & 10. Monthly records were complete and appeared valid. These sources are grouped in
the logbook,but VE observations are made at the individual sources. 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).
Mr. Wallace stated that he observes both openings, fbr each side of the building, during the
monthly observation. We discovered that one conveyor in the grinding operation is in separate
building (milling bldg) from the rest of the subject sources which require VE observations. Mr.
Wallace has not been observing the milling building for VE as he has been for the grinding
building. This is obviously an over-site, and he will begin observing the milling building opening
for VE on the same frequency as the grinding building. The logbook will reflect that he does the
VE observations on the two buildings. 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).
Mr. Wallace stated that he observes both openings, for each side of the building, during the
monthly observation. 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—The tanks currently listed as subject to this rule all (except T-
5) contain petroleum products such as fuel oils for off road use and do not appear to be subject to
NSPS Kb. It appears that NSPS Subpart Kb has been applied in error to vessels T-1 thru T-4. The
applicability of NSPS Kb for vessel T-5 will be determined after additional research on the contents
of that vessel.
1. 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. Mr. Maxwell stated that they have not received any complaints
from citizens, nor has DAQ received any complaints.
J. 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 #1 at just over 50%
capacity, which is—30-35% of the facility's total capacity. The highest hourly rate during the last
12 months was 14.6 TPH. Quarterly reports have been received on time and appear complete and
valid.

K. 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 2011 EI, plus the current
and last 12 months' operating rates,Triangle Brick TAP emissions are below the listed TPERs.
L. 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 — Fuel oil has not been combusted since January 2010. S02
emissions for CY 2012 were far below the limit. Highest hourly production rate in CY 2011 was
14.6 TPH. Quarterly reports have been received on time and appear complete and valid.
112r STATUS:
Based on visual observations and past personnel interviews, this facility is subject only to the general
provisions of the 112r regulation.
FIVE YEAR COMPLIANCE HISTORY:
No compliance issues during the last 5 yrs.
CONCLUSIONS AND RECOMMENDATIONS:
Based on the observations made during the 29 January 2013 compliance inspection, Triangle Brick Co-
Wadesboro appeared to be in compliance with the requirements in their current air permit.
• Recommend removing applicability of NSPS Kb to vessels T-1 thru T-4. Do further research on
T-5.
• Compliance with 2D .0515 was based on 3/14/06 ST results and included only PM filterable.
Recommend any new testing include condensibles and consideration of organics.
/hsh