AQ_F_0400043_20110118_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: 01/31/2011
Facility Data Compliance Data
Triangle Brick Co -Wadesboro Inspection Date 01/18/2011
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
Inspecto's Signature: n Comments:-
Date of Signature:
1. NIACT/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 a Dry Lime Adsorber(DLA)to reduce HF
emissions below TV thresholds. This way they can avoid being subject to the Brick MACT, whenever it is
re-promulgated. They have no generators on site,and therefore are not subject to the Reciprocating Internal
Combustion Engine(RICE) NJACT(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 thm Wadesboro. On the west side of Wadesboro, turn
right,following US52 north. Go approximately 3.5 miles and nun right into the first facility entrance;the
office is on the left. Check opacities prior to entering(DLA stack, openings in bldg with grinders).
3. 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.
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 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 clays. 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 18 January 2011,Robert Hayden and I,Heather Hawkins,met with Paul Maxwell,Plant Manager,to do
a compliance inspection. Mr.Nathan Wallace,Kiln Supervisor,provided and discussed the records.
Triangle is currently operating at—25% capacity(one kiln operating at 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. The facility
currently employs approx 49 people and the kiln(s)operate 24/7.
6. 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 CD-Kl** Dry Limestone
oil-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 CD-K2* Dry Limestone
oil-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
7G-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-I Loam/sawdust feeder N/A N/A
LS-2 One conveyor from loatiV 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
7. PERMIT EXEMPT EMISSION SOURCES:
AWssion Soulr6e ID No. ' Emission Source DesGi-i tiou
IS-Tank 1 3,000 gallon above ground gasoline storage tank
8. 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.
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 Ibs/ton, or 10.25 Ibs/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 3 Jan 2011. 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; however,there are still
no recorded incidents of needed maintenance, deviations or equipment malfunctions. Mr. Maxwell and
Mr. Wallace said they would make the necessary changes. The last semiannual report was received on
time and appeared complete and valid.
INSPECTOR'S NOTE: The facility made some changes to recordkeeping since the last inspection in
regards to the inspector's concerns. However, the records still appear somewhat "artificial. " There are
still no recorded incidents of needed maintenance, deviations or equipment malfunctions. Sources are
groupedfor various inspections and observations, but there is nothing to indicate which sources are in
the groups, or where and how the insp and obs are made.. There is still no language describing what a
"normal"opacity looks like, and nothing citing the initial 30-day period when it was determined. Mr.
Wallace said he would make the necessary changes.

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 Ibs/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.
IN COMPLIANCE-Kiln#1 is currently operating on NG,and only combusted 22,321 gal of No.2 fuel
oil in last 12 months(Jan 2010). Since 2007,the facility has only received one shipment of No. 6 fuel oil
and has not combusted any of it to date. 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.
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. I 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; however,there is still no language describing what a"normal" opacity looks like. 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 an
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.
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"normal." I explained
to Mr. Maxwell and Mr. Wallace that the requirement is to observe for any VE, not normal vs abnormal.
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 13 Jan 2011.
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.
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. 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. However,there is
still no language describing what a"normal"opacity looks like. 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 #I 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.
IN COMPLIANCE—The facility has chosen to observe the building openings monthly using a like
Method 22. 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
now observes both openings,for each side of the building, during the monthly observation. The monthly
observation records all indicated"normal." I explained that the permit requirement, since they elected to
ohs at the building openings, is to observe for any VE coming from the building opening. Mr. Wallace
stated that he understood and would make the necessary changes to the recordkeeping format. 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.
IN COMPLIANCE—The facility has chosen to observe die building openings monthly using a like
Method 22. 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
now observes both openings,for each side of the building, during the monthly observation. The monthly
observation records all indicated"normal." I explained that the permit requirement, since they elected to
obs at the building openings, is to observe for any VE coming from the building opening. Mr. Wallace
stated that lie understood and would make the necessary changes to the recordkeeping format. 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.
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-I thm 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.
IN COMPLIANCE—No odor, associated with this facility, was noticed when entering or exiting the
property.
J. 15A NCAC 2D .I100 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 kilos, K-1 and K-2, to 58,000 Ibs/hour(29 TPH). Quarterly summary reporting
to DAQ
IN COMPLIANCE—Triangle is currently operating Kiln 41 at— 50% capacity,which is—25% of the
facility's total capacity. The highest hourly rate during the last 12 months is 11.9 TPH. Reports have
been received on time and appear accurate and complete.
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.
IN COMPLIANCE—Based on emissions reported in the 2009 EI, plus the current and last 12 months'
operating rates,Triangle Brick TAP emissions are below the listed TPERs with the exception of fluorides
TPER error noted in the 2010 inspection report.

IN COMPLIANCE—Based on emissions reported in the 2009 EI,plus the current and last 12 months'
operating rates, Triangle Brick TAP emissions are below the listed TPERs with the exception of
fluorides TPER error noted in the 2010 inspection report.
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.
IN COMPLIANCE—Fuel oil has not been combusted since 2007,and the current production rates are
far below the monthly triggers. The last report was received on time and indicated compliance.
9. COMPLIANCE HISTORY:
June 2002—NOV—Late reporting
Sept 2002—NOV—Failure to complete NSPS performance testing
Nov 2003 —NOV—Late reporting
Sept 2005 —NOV—Late reporting
Dec 2005 —NOV—Failure to complete NSPS performance testing
10. CONCLUSIONS AND RECOMMENDATIONS:
Based on the observations made during the 18 January 2011 compliance inspection, Triangle Brick
appeared to be in compliance with the requirements.
Recommend removing vessels T-1 thru T-4 from permit as subject to NSPS Kb. Do further research on
T-5.
/hsh