AQ_F_0400043_20120307_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: 03/08/2012
Facility Data Compliance Data
Triangle Brick Co-Wadesboro Inspection Date 03/07/2012
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 12/11/2007
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: fol
MACT/GACT APPLICABILITY:
Triangle Brick Co — Wadesboro facility was subject to the Brick MACT (Subpart JJJJJ), until it was
vacated. Now they are seeking a synthetic minor status by using Dry Lime Adsorbers (DLA) to reduce
HF emissions below TV thresholds. This way they can avoid being subject to the Brick MACT,
whenever it is re-promulgated or 112j. They have no generators on site, and therefore are 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 7 March 2012, I 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%) as the housing construction slow-down has
lowered the demand for brick. 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.
Mr. Wallace stated that he is not currently VE certified. I told him I needed to research the matter to
determine if he is required to be certified when making the daily/weekly/monthly VE observations. I
reviewed the rule and spoke with Robert Hayden, Compliance Coordinator, and learned that it is not
required that Mr. Wallace be certified in order to make the observation,but that as soon as they trigger the
Method 9 requirement the observer must be certified. I communicated this to Mr. Maxwell on 13 March
2012.
The facility's application for permit renewal is currently in-house at RCO and lumped together with their
application for HAP minor status, pending results from requested modeling. The renewal application has
been lapped(meaning the renewal was never issued before another renewal was due) and the HAP minor
application has been in process for almost 3 years.
PERMITTED EMISSION SOURCES:
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. III 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:
Emission Source ID No. I Emission Source Description
IS-Tank 1 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 35.4 lbs/hour
at a production rate of 25 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.
APPEARS IN COMPLIANCE — Facility operates on NG with fuel oil as backup. They haven't
used fuel oil since 2007. The AP-42 factor for particulates from a natural gas fired kiln is 0.37
lbs/ton, or 10.25 lbs/hour. During the inspection, I reviewed the I&M records documenting internal
and external inspections that were conducted semi-annually, the latest inspection was conducted on
10 Jan 2012. Facility personnel modified the recordkeeping format since the last inspection to
address the inspector's concerns. The sources that are grouped for observations are now clearly

identified on the record. The last semiannual report was received on time and appeared 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.
APPEARS 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, 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 point once each month for normal vs abnormal, and submit semiannual
summary rpts to DAQ.
APPEARS IN COMPLIANCE—During the inspection, Kiln#1 was operating and I observed 0%
VE from the common kiln stack at the DLA. 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). Facility personnel modified the recordkeeping format since the last inspection to
address the inspector's concerns. The last semiannual report was received on time and appeared
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.
APPEARS IN COMPLIANCE —All notifications have been completed. During the inspection I
reviewed the logbook of daily VE observations made at the building opening; 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, most recent inspection conducted on 23 Jan 2012.
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.
APPEARS 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. Facility personnel modified
the recordkeeping format since the last inspection to address the inspector's concerns. Sources
grouped for various inspections and observations are now clearly identified. The crushing

operations were not operating during the inspection. The last semiannual report was received on
time and appeared complete and valid.
F. 15A NCAC 2D .0524 NEW SOURCE PERFORMANCE STANDARDS SUBPART 000 -
For the Kiln#1 clay grinding 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 the Kiln #2 clay
grinding plant scalp screens, finish screens, hammer mill, storage bins, feeders and conveyors (ID
Nos. CG-30 through CG-55), 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.
APPEARS 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." The last semiannual report was received on time and appeared
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.
APPEARS 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." The last semiannual report was received on time and appeared
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.
APPEARS 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.
I. 15A NCAC 2D .1806 CONTROL AND PROHIBITION OF ODOROUS EMISSIONS —The
Permittee shall not allow objectionable odors to extend beyond the facility's boundary.
APPEARS IN COMPLIANCE—No odor, associated with this facility, was noticed when entering
or exiting the property.
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.

APPEARS 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 11.5 TPH. 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.
APPEARS IN COMPLIANCE—Based on emissions reported in the 2010 EI,plus the current and
last 12 months' operating rates, Triangle Brick TAP emissions are below the listed TPERs.
Flourides TPER excludes HF, therefore it appears that there is no error in the TPER table as
thought to be the case since the CY 2010 inspection.
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.
APPEARS IN COMPLIANCE—Fuel oil has not been combusted since 2007. S02 emissions for
CY 2011 were 24 tons, far below the limit. Highest hourly production rate in CY 2011 was 11.5
TPH. The last report was received on time and appeared 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 7 March 2012 compliance inspection, Triangle Brick Co-
Wadesboro appeared to be in compliance with the requirement of their current air permit.
Recommend removing vessels T-1 thru T-4 from permit as subject to NSPS Kb. Do further research on
T-5.
/hsh