AQ_F_1900009_20220223_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Raleigh Regional Office
AIR QUALITY General Shale Brick,Inc. -Moncure Facility
NC Facility ID 1900009
Inspection Report County/FIPS: Chatham/037
Date: 02/23/2022
Facility Data Permit Data
General Shale Brick,Inc. -Moncure Facility Permit 04384/R40
300 Brick Plant Road Issued 7/29/2021
Moncure,NC 27559 Expires 6/30/2029
Lat: 35d 34.3530m Long: 79d 2.0830m Class/Status Synthetic Minor
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
J.Warren Paschal Kevin Ham J.Warren Paschal NSPS: Subpart 000
Manager of VP Engineering& Manager of
Environmental Research Environmental
Compliance [phone] Compliance
919 774-6533 919 774-6533
Compliance Data
Comments: Compliance inspection—Appears to be in compliance.
Inspection Date 02/23/2022
Inspector's Name Jeff Harris
Inspector's Signature: C Operating Status Operating
Compliance Status Compliance-inspection
Action Code FCE
Date of Signature:2/23/2022 Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2020 48.34 0.6000 23.40 3.49 59.55 46.55 2745.47
2019 60.57 0.7500 29.22 4.19 74.32 58.11 3426.70
*Highest HAP Emitted inpounds)
Five Year Violation History:
Date Letter Tyne Rule Violated Violation Resolution Date
09/24/2021 NOV Permit Late Title V ACC 10/13/2021
Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested
(I)DIRECTIONS: General Shale Brick's Moncure Facility(General Shale)is located off Corinth Road in Moncure, Chatham
County. From Raleigh,take the beltline to US-1 South. Follow US-1 South for 17 miles to the exit for Old US 1 South. Turn
right off the exit ramp onto SR 1011. Travel approximately 4 miles and take a left onto Corinth Road(SR 1923). The facility
is approximately 4 miles down Corinth Road on the right.

(II)FACILITY DESCRIPTION: General Shale produces various sizes and styles of bricks at their Moncure facility. Clay is
transported to the plant from nearby mines,processed to a fine texture, and then extruded into bricks. The bricks then are
texturized prior to entering one of the brick kilns.
There are four brick kilns at the Moncure facility,two of which are older wood-fired kilns(Kilns 1 and 2)and two of which are
newer kilns(Kilns 3 and 4). Kilns 4 was converted from coal to natural gas in 2015 and Kiln 3 is currently not operational since
the coal fuel system has been removed. Plans have been drafted to convert Kiln 3 to natural gas as their primary fuel like Kiln
4,but the conversion is on indefinite hold due to economic considerations. All the kilns have four distinct zones: the drying
zone,the preheating zone,the firing zone, and the cooling zone. After exiting the kilns,the bricks are packaged for shipping.
Note: Kilns 1 and 2 are also referred to as the Cape Fear plant or Plant#24,and Kiln 3 and 4 are referred to as the Brickhaven
plant or Plant#25. The Cape Fear plant has not operated since 2007 and is unlikely to operate again.
The facility permit/fee class has changed from Title V to Synthetic Minor with issuance of permit 04384R40 on 6/29/2021.
Alternative operating scenarios for coal use have been removed, along with the coal processing system, grinding and screening
operations,block plant, and sand silo systems.
Safety Note: Standard personal protective equipment for this facility would include,but not limited to,hard hat, safety glasses,
hearing protection, and safety shoes.
(III)INSPECTION SUMMARY: On February 23, 2022,I(Jeff Harris)met with Mr. Warren Paschal,Manager of
Environmental Compliance for General Shale, for the purpose of conducting an air quality permit compliance inspection.
Before the on-site inspection,Mr. Paschal provided most necessary records via e-mail. All records were complete and up to
date. Mr. Paschal indicated that as in previous years,the conversion of Kiln 3 from coal to natural gas has not occurred and the
unit remains idle with all coal fuel having been removed from the facility. On my arrival,Mr. Paschal and I toured the facility.
At the time of my inspection,the only brick tunnel kiln operating was Kiln 4 and it appeared to be operating well from an air
quality standpoint with opacity of zero percent from the DLA stack. It was operating on a schedule of—24 cars/day or 16.12
tons/hour. Comments about observations made during the inspection are provided below for each of the emission sources and
specific conditions listed in the facility's current air permit.
(IV)PERMITTED EMISSION SOURCES: At the time of the inspection, General Shale's Moncure Plant was operating
under Air Permit No. 04384R40,which was issued on July 29,2021, expires on June 30,2029,and includes the following
emission sources and control devices:
A. Brick tunnel kilns 11 2, 3, and 4 and associated dryers consisting of
Two wood/natural gas-fired brick tunnel kilns (27 million Btu per hour maximum heat input rate
and 13.7 tons per hour maximum fired brick production rate, each, ID Nos. ES-KI and ES-K2)
and associated sawdust rotary dryer(ID No. ES-WD1,2);
One natural gas/propane-fired brick tunnel kiln (25.9 million Btu per hour maximum heat input rate
and 20.55 tons per hour maximum fired brick production rate, ID No. ES-K3K) and associated dry
limestone adsorber(ID No. CD-K3DLA) and the three associated natural gas/propane-fired brick
dryers (ID Nos. ES-K3D1, ES-K3D2, and ES-K3D3); and
One natural gas/propane-fired brick tunnel kiln (25.9 million Btu per hour maximum heat input rate
and 20.55 tons per hour maximum fired brick production rate, ID No. ES-K4K) and associated dry
lime injection fabric filter(ID No. CD-K4DIFF) and the three associated natural gas/propane-fired
brick dryers (ID Nos. ES-K4D1, ES-K4D2, and E4-K3D3);
Kilns I and 2 and associated equipment are listed in the permit as inactive,with notification required upon
startup. Kiln ES-K4K was the only kiln in operation at the time of my inspection and it was firing natural
gas. I did not observe any visible emissions (VE) from the DLA stack and no VE from the dryer stacks. At
the time of my inspection the kiln was operating on schedule of—24 cars/day or 16.12 tons/hour.

B. One wood fuel/sawdust system consisting of two 8 x 8 screen, cyclone, hammermill, sawdust silo,
surge hopper, transfer screw conveyor, screen feed conveyor, and enclosed conveyor(ID Nos. ES-
WFS-SD-SCI, ES-WFS-SC2, ES-WFS-SD-CYC, ES-WFS-SD-HM, ES-WFS-SD-SDS, ES-WFS-SD-
SH, ES-WFS-SD-CVI, ES-WFS-CV2, and ES-WFS-SD-CV3) controlled by two dust collectors, one
cyclone, and two bin vent filters (ID Nos. CD-SD-DC], CD-SD-DC2, ES-WFS-SD-CYC, CD-SD-
BVI, and CD-SD-BV2);
This equipment is listed in the permit as inactive,with notification required upon startup. It was not
operating at the time of my inspection. The facility no longer uses wood as fuel.
C. Natural gas-fired coatings rotary dryer(3.45 tons of coatings per hour maximum drying capacity,
250,000 Btu per hour firing rate, ID No. ES-CD-8);
This equipment was not operating at the time of my inspection but had been operating earlier in the
day. The coatings dryer dries the coating material itself,prior to its application to the uncured
bricks, so its operation is intermittent.
D. Two texturizing operations (ID Nos. ES-CR5 and ES-CR6) controlled by two bagfilters (6,096 and
3,040 square feet of filter area, respectively, ID Nos. CD-CR6BF and CD-CR6BF2), one
texturizing operation (ID No. ES-CR7) controlled by two bagfilters (6,096 and 4,062 square feet of
filter area respectively, ID Nos. CD-CR7BF and CD-CR7BF2), and sand silo system (ID No. ES-
SS) controlled by one bin vent filter(ID No. CD-SS-BV3);
The texturizing equipment associated with Kiln 4 was operating at the time of my inspection.
ES-CR5 &CR6 are associated with Kilns 1 &2 and are listed in the permit as inactive,with
notification required upon startup.
E. Clay crushing, grinding, and screening operations including one NSPS-affected primary crusher
(ID No. F-PC), two NSPS-affected scalping screens (ID Nos. F-SSI and F-SS2), one NSPS-affected
hammermill (ID No. F-HM), two single deck finishing screens (ID Nos. F-FSI and F-FS2), one
bank of seven finishing screens (ID Nos. F-FS3, F-FS4, F-FS5 through F-FS9), two NSPS-affected
finishing conveyors #4 and #5 (ID Nos. F-FC4 and F-FC5), and one NSPS-affected intersite
conveyor(ID No. F-C-CFBH);
This equipment was not operating at the time of my inspection, due to maintenance on the
hammermill. It was expected to be back in service later in the day.
(V) SPECIFIC PERMIT CONDITIONS:
A.I Facility shall comply with Title 15A North Carolina Administrative Code (NCAC), Subchapter 21) .0202, 21) .0515, 2D
.0516, 21) .0521, 2D .0524 (40 CFR 60, Subpart 000), 21) .0535, 21) .0540, 21) .0605, 2D .1100, 2D .1806, 2Q .0315 and
2Q .0711.
Appears to be in compliance. See details in the following sections.
A.3 15A NCAC 2D .0515: PARTICULATE FROM MISCELLANEOUS INDUSTRIAL PROCESSES—Particulate matter
emissions from the emission sources shall not exceed allowable emission rates, which are a function of the process weight
rate.

Appears to be in compliance-The particulate emission limit for each of the subject emission sources is determined
based on the individual process weight rates for the sources. No particulate emission testing is required by the
facility's air permit. To ensure compliance with the particulate emission limit,the facility is required to conduct
monthly and annual inspections on all control devices and semiannual inspections on the brick kilns. The facility is
required to keep records of all inspection and maintenance activities. The inspection and maintenance records
appeared to be adequate.
A.4 15A NCAC 2D.0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES-Sulfur dioxide emissions
from the combustion sources shall not exceed 2.3 pounds per million Btu heat input.
Appears to be in compliance - The sulfur dioxide emission limit for each of these sources is 2.3 pounds per
million Btu heat input. No testing is required by the facility's air permit. No monitoring/record keeping/reporting
is required for the combustion of wood,natural gas, and propane in the combustion equipment.
A.5,6 15A NCAC 0521: CONTROL OF VISIBLE EMISSIONS-
Appears to be in compliance - The visible emission limit for the Kilns 1 and 2 (ID No. ES-K1 and ES-K2 -
INACTIVE), the sawdust dryer (ID No. WD1,2- INACTIVE), the coatings dryer (ID No. ES-CD- INACTIVE),
and two of the texturing operations (ID Nos. ES-CD5 and ES-CD6 - INACTIVE) is 40 percent opacity. Kilns 1
and 2 and their associated sources are not operating and are listed in the permit as inactive, with notification
required upon startup.
The visible emission limit for all other emission sources is 20 percent opacity. During the inspection, all of the
emission sources observed in operation appeared to be meeting their respective 2D .0521 visible emissions
standard.
No visible emission testing/monitoring/record keeping/reporting is required for any of emission sources.
A.7 15A NCAC 2D .0524: NEW SOURCE PERFORMANCE STANDARDS (40 CFR 60, Subpart 000)
Appears to be in compliance - To comply with the requirements of Subpart 000, the facility must maintain
particulate and visible emissions below the source specific limits defined in the permit, or if an affected facility is
enclosed in a building, the building enclosing the affected facilities must comply with a visible emissions limit of
seven (7) percent opacity from the building openings (except for vents as defined in 60.671) and a particulate
emission limit of 0.014 grains per dry standard cubic foot from the vents. The facility must also record the results
of the monthly observations in a. Upon request, plant personnel were able to provide me with records of monthly
visible emission observations.
A.9 15A NCAC 2D .0540 "Particulates from Fugitive Dust Emission Sources
Appears to be in compliance - As required by 15A NCAC 2D .0540, the Permittee shall not cause or allow
fugitive dust emissions to cause or contribute to substantive complaints or excess visible emissions beyond the
property boundary. I observed no fugitive dust during the inspection;no complaints are on file against the facility.
A.11 15A NCAC 2D .1100 and 2Q .0711: TOXIC AIR POLLUTANT REQUIREMENTS - All of the permitted
emission sources are subject to 2D .1100 and 2Q .0711.
Appears to be in compliance - In conjunction with a prior permit application, the permittee submitted air
modeling results that demonstrated that emissions of the Toxic Air Pollutants (TAPs) listed in the permit were
below state Ambient Air Standards (AALs) beyond the fence line of the facility. To comply with 2D .1100, the
permittee must maintain operational records to ensure that the operational restrictions outlined in the permit are
met. These restrictions are 54,800 pounds of brick per hour for Kilns 1 and 2 and 82,200 pounds of brick per hour
for Kilns 3 and 4. During Q4 of calendar year 2021, the highest production rate for Kilns 1&2 was zero pounds
of brick per hour and the highest production rate for Kilns 3&4 was 37,925 pounds of brick per hour. The facility

is required to submit quarterly reports demonstrating compliance with the operational restrictions. All recent
quarterly reports have been submitted on time and have demonstrated compliance with the toxics operational
limits.
To ensure proper operation of the Dry Lime Adsorbers,the facility must:
1. Monitor and record electronically the bypass damper position associated with the DLAs(ID Nos.
CD-K3DLA and CD-K4DLA) at least every 15 minutes.Alternatively, a daily report showing the
amount of open and/or closed time for the previous 24 hours may be generated from the plant
computer. As a third alternative,manual log sheets may be used. The reason for each bypass
event shall also be recorded in a logbook.
2. Verify that the limestone hopper and storage bins(located at the top of the DLAs) contain
adequate limestone by performing a daily visual check and recording the results in a logbook.
3. Record the limestone feeder setting daily in logbook to verify that the feeder setting is being
maintained at or above 30 pounds per hour.
4. Maintain records of the source and type of limestone utilized in the DLAs (ID Nos. CD-K3DLA
and CD-K4DLA)during the most recent performance test in a logbook.
5. Monitor and record operating uptime of the brick tunnel kilns (ID Nos. ES-K3K and ES-K4K)
and the downtime associated the routine control device maintenance of the DLAs(ID Nos. CD-
K3DLA and CD-K4DLA).
Upon request,the facility provided records demonstrating compliance with these requirements.
A.12 15A NCAC 2D.1806: CONTROL AND PROHIBITION OF ODOROUS EMISSIONS—All of the permitted
emission sources are subject to 2D .1806.
Appears to be in compliance - To comply with 2D .1806, the Permittee shall not operate the facility without
implementing management practices or installing and operating odor control equipment sufficient to prevent
odorous emissions from the facility from causing or contributing to objectionable odors beyond the facility's
boundary. No objectionable odors were detected during the compliance inspection. No odorous emissions
testing/monitoring/record keeping/reporting is required by the facility's air permit.
A.13 LIMITATION TO AVOID 15A NCAC 2Q .0501 "Synthetic Minor Facilities,"
Facility-wide emissions shall be less than the following:
Pollutant Emission
(Tons per consecutive 12-month
M10 1100
Total HAPs 125
Individual HAPs 110
a. Operation Restrictions -When any permitted equipment marked as "INACTIVE" in the emission
source table becomes operational, these sources shall be operated such that facility-wide PM10
emissions remain below 100 tons per year, total HAP emissions remain below 25 tons per year,
and hydrogen chloride (HCl) and hydrogen fluoride (HF) emissions remain below 10 tons per
year, each.

b. Inspection and Maintenance Requirements — The facility shall perform periodic inspections and
maintenance (I&M) as recommended by the manufacturer. In addition, the Permittee shall
perform an annual (for each 12-month period following the initial inspection) internal inspection
for Fabric Filters and Cyclones, and maintain a logbook of these inspection, maintenance, and
monitoring requirements.
Appears to be in compliance—Upon request, the facility provided copies of the required records demonstrating
compliance.None of the inactive equipment is currently in operation.
(VI)EXEMPT EMISSION SOURCES: The facility currently has several emission sources listed on the facility's insignificant
activities attachment to the permit. No concerns were noted during the inspection with regard to these sources. Additionally,no
additional exempt emission sources were observed that would need inclusion on the permit's insignificant activities list.
(VII)COMPLIANCE HISTORY: General Shale Moncure has received two Notices within the last five years. On July 26,
2006, an NOV/NRE was issued to the facility for not maintaining the required pressure drop across the dry limestone adsorber
(DLA) (ID No. CD-K4DLA). On December 21, 2006, an NOV was issued to the facility for several missed recordings of the
daily limestone feeder setting for the same dry limestone adsorber. On March 7,2008, a Notice of Continuing Violation was
issued to the facility for combusting coal in the Kiln ES-K4K without using the required dry lime injected fabric filter(CD-
K4DIFF). The facility received a civil penalty assessment of$5473.00 on December 3,2008. On March 25,2009, an NOV was
issued for a late semiannual report. On August 26,2021, an NOD was issued to the facility for a late quarterly report. On
September 24,2021, an NOV was issued to the facility for a late partial year ACC.
(VIII)EMISSIONS INVENTORY REVIEW: Brick production for 2020 was down 20 percent from the brick production in
2019 and that accounts for the percent change for the pollutants emitted in 2020.
(IX) CLEAN AIR ACT SECTION 112(r)REQUIREMENTS: Pursuant to 15A NCAC 2D .2100 "Risk Management
Program," if the Permittee is required to develop and register a risk management plan pursuant to Section 112(r)of the Federal
Clean Air Act,then the Permittee is required to register this plan with the USEPA in accordance with 40 CFR Part 68.
RMP Not Required—General Shale is subject to the 112(r)program general duty clause,but does not maintain regulated
chemicals onsite above the threshold quantities,which would require a risk management plan.
(X) STACK TEST HISTORY: According to the IBEAM database,the most recent stack test performed at this facility was
performed on September 24,2015. Prior to that, a stack test was performed in February of 2006. Both tests involved brick
tunnel kiln 4(ES-K4KO).
(XI) CONCLUSIONS/RECOMMENDATIONS: Based on this inspection,General Shale's Moncure facility appears to be in
compliance with all applicable requirements. It is also recommended that this facility be re-inspected in one year.