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HomeMy WebLinkAboutAQ_F_0400043_20210101_CMPL_CompRpt REVIEW OF TITLE V 2020 ANNUAL COMPLIANCE CERTIFICATION Reviewer Assigned: Evangelyn Lowery-Jace FACILITY Triangle Brick Company-Wadesboro Brick FACILITY 0400043 NAME: Manufacturing Plant ID: 1. Is the Certification sheet signed by the authorized/responsible official? Y V N ❑ 2. Print the"Summary of Violations for a Facility"report from IBEAM and attach. W1 3. Are all NOD/NOV/NREs accounted for in the Deviation Summary Report? Y V N ❑ N/A 4. If deviations are noted, did FRO address them all?(i.e. send letter)? Check paper file for any issues that may not be recorded in IBEAM Violations. Y[:] N❑ N/AFV(] 5. Discuss deviations details with Compliance Coordinator. Y❑ N/A[,V(] 6. If there was more than one permit applicable during the year, have all the permits been addressed in this ACC? Permit Numbers 08179T11 Y Fv-(] N❑ N/A❑ 7. Do reported sources and conditions match those in the permit(s)? Y 7 N❑ 8. Is the Compliance Summary Report for Specific Conditions complete and accurate? Y V N❑ 9. Is the Compliance Summary Report for General Conditions complete and accurate? Y V N ❑ 10. Is compliance with the ACC requirements indicated? Y V N ❑ 11. Record in IBEAM Actions/Reporting(date received, date reviewed,compliance status,comments). Completed on 02/18/2021 (date) REMEMBER—Compliance determination here refers to the ACC submitting requirements(late, not submitted, incomplete, etc). Talk.to the Compliance Coordinator before you code a facility in violation. 12. Initial and date the top of the ACC Certification Sheet(not this cover sheet). F-1 13. File FRO copy in a"Reports"or an"ACC"folder in facility file after Compliance Coordinator review. 14. Comments: Reviewed by: ELJ Date: 211812021 (initials) Coordinator Review: JDC Date 211812021 (initials) 03/10/2021 Page 1 of 2 Summary of Violations Violator: Triangle Brick Company - Wadesboro Brick Manufacturing Plant Facility ID: 0400043 Letter Date(s): 05/11/2017 Violation(s): County: Anson Letter Type: NOD-report Case#: Date Assessed: Amount Assessed: Case Closed: Total Amount Paid: $0.00 Letter Date(s): 08/26/2016 Violation(s): County: Anson Letter Type: FYI/Facilities Case#: Date Assessed: Amount Assessed: Case Closed: Total Amount Paid: $0.00 Letter Date(s): 09/30/2009 Violation(s): County: Anson Letter Type: FYI/Facilities Case#: Date Assessed: Amount Assessed: Case Closed: Total Amount Paid: $0.00 Letter Date(s): 12/21/2005 Violation(s): 2D .0524 New Source Performance Standards County: Anson Letter Type: NOV Case#: Date Assessed: Amount Assessed: Case Closed: Total Amount Paid: $0.00 Letter Date(s): 09/06/2005 Violation(s): Permit Late Report(excluding ACC) County: Anson Letter Type: NOV Case#: Date Assessed: Amount Assessed: Case Closed: Total Amount Paid: $0.00 Letter Date(s): 05/10/2005 Violation(s): County: Anson Letter Type: FYI/Facilities Case#: Date Assessed: Amount Assessed: Case Closed: Total Amount Paid: $0.00 Letter Date(s): 03/09/2005 Violation(s): County: Anson Letter Type: FYI/Facilities Case#: Date Assessed: Amount Assessed: 03/10/2021 Page 2 of 2 Summary of Violations Violator: Triangle Brick Company - Wadesboro Brick Manufacturing Plant Facility ID: 0400043 Case Closed: Total Amount Paid: $0.00 Letter Date(s): 09/22/2004 Violation(s): County: Anson Letter Type: FYI/Facilities Case#: Date Assessed: Amount Assessed: Case Closed: Total Amount Paid: $0.00 Letter Date(s): 09/25/2002 Violation(s): 2D .0524 New Source Performance Standards County: Anson Letter Type: NOV Case#: Date Assessed: Amount Assessed: Case Closed: Total Amount Paid: $0.00 Letter Date(s): 08/13/2002 Violation(s): County: Anson Letter Type: FYI/Facilities Case#: Date Assessed: Amount Assessed: Case Closed: Total Amount Paid: $0.00 Letter Date(s): 06/17/2002 Violation(s): Permit Condition(s) late report County: Anson Letter Type: NOV Case#: Date Assessed: Amount Assessed: Case Closed: Total Amount Paid: $0.00 6� W1 FEB - 120A REGFIVF D t' Triangle Brick ®EQ-FAYETTEMLLE REGIONAL OFFICE 6523 NC Highway 55 January 22, 2021 Durham, NC 27713Durham (919)544-1796 Raleigh: (919)828-2070 Toll Free: 800-672-8547 North Carolina Department of Environmental Quality Fax: 800-849-0612 Fayetteville Regional Office Division of Air Quality 225 Green Street-Suite 714 Fayetteville, North Carolina 28301-5043 Attention: Heather Carter Fayetteville Regional Air Quality Supervisor Reference: 2020 Annual Compliance Report for Permit 08179T11 Triangle Brick Company—Wadesboro Wadesboro, North Carolina Dear Ms. Carter: Enclosed please find the semi-annual compliance report for our Wadesboro facility due on January 30, 2021. Attachment 1 includes the statement of certification from the Responsible Official and details the annual requirements of the Title V permit and the facility's method of compliance. Attachment 2 details the facility-wide emissions of hazardous air pollutants. Attachment 3 includes the Bypass Damper Position Report. This report is for Title V Permit No. 08179T11, for the reporting period of January 1 through December 31, 2020. It is our belief that the attached information meets the reporting requirements as specified in our air permit. However, should you require additional information, please do not hesitate to contact me at (919) 544-1796 or by email at HowardB@trianglebrick.com. Sincerely, TRIANGLE BRICK COMPANY //111 AA ,/� Howard P. Brown,Jr. President and CEO cc: Heather Ceron—US EPA Region 4 cc: David Gibson—Triangle Brick Company Attachments Certification by Responsible Official Based on information and belief formed after reasonable inquiry, the undersigned certifies under penalty of law(federal rule 40 CFR 70.5(d))that all information and statements provided in this report(including any attachments)are true, accurate, and complete. (Signature of Responsible Official) (Date) Name: Howard P. Brown, Jr. (Type or Print) Attachment 1 Certification and Annual Compliance Report North Carolina Department of Environmental Quality Division of Air Quality(DAQ) Title V Annual Compliance Certification Forms(1) Facility Name: Triangle Brick Company Facility Location: US Highway 52, Wadesboro,NC 28170 Facility ID Number: 0400043 (Refer to first page of Title V Permit) Title V Permit Number: 08179T 11 (Refer to first page of Title V Permit) Start of Reporting Period: January 1,2020 (Month,Day,Year) End of Reporting Period: December 31,2020 (Month, Day,Year) Compliance Statement (Check only one of the following options) X During the reporting period specified above,this facility was in compliance with all terms and conditions identified in the above referenced Title V Operating Permit. As such, there were no deviations(2), excess emissions events, or other reportable incidents including those attributable to equipment malfunctions, breakdown, or upset conditions (please fill out the Compliance Summary Report). During the reporting period specified above, this facility was in compliance with ALL terms and conditions identified in the above referenced Title V Operating Permit, EXCEPT for the deviations(2) identified in the Deviation Summary Report(please fill out both the Compliance Summary Report and Deviation Summary Report). Does the above compliance statement differ from what is indicated on your most rece Title V Report(i.e. last Semi-Annual Monitoring Report, Annual Emissions Inventory, etc)? Yes No Are you submitting this Annual Compliance Certification form to also fulfill a Titl Semi-Annual Monitoring reporting requirement? If so, this certification must be submitted by January 30. Yes No Certification BY Responsible onsible Official Based on information and belief formed after reasonable inquiry, the undersigned certifies under penalty of law (federal rule 40 CFR 70.5(d))that all information and statements provided in this form(including any attachments) are true, accurate, and complete. P,/—� /7�_ _ -Z� (Signature of Responsible Official) (Date) Name: Howard P. Brown,Jr. (Type or Print) Number of Pages Attached 29 1An annual compliance certification(ACC)is required pursuant to federal rule 40 CFR 70.6(c),state rules 15A NCAC Sections 2Q.0508(t)and 2Q.0508(bb), and Section 3-General Condition P of the Title V Operating Permit. A copy of your ACC is to be submitted to both the forth Carolina DAQ and the US.EPA(Air and EPCRA Enforcement Branch,EPA,Region 4,61 Forsyth Street,Atlanta,GA 30303). The submittal date for the ACC is specified in Section 3-General Condition P of your Title V permit. 2 For the purposes of this form,the term "deviation"means any action or circumstance not in accordance with the terms and conditions of the Title V Operating Permit including those attributable to equipment malfunction, breakdown,or upset conditions and/or excess emissions events. The acknowledgement of deviations from speck permit requirements is not necessarily an acknowledgement of a violation. However,failure to report any and all deviations may constitute a violation of the Title V Operating Permit and the underlying emission standard For more information about deviations,please refer to the DAQ memorandum outlining the definition of deviation for Title hreporting on the DAQ web site(http://d`eq.nc.govlabout/divisions/air-quality/air-quality-enforcementlexcess-emissions-deviations-malfunction-determinations). Revision 3.0 i Page 1 of 29 North Carolina Department of Environmental Quality Division of Air Quality COMPLIANCE SUMMARY REPORT For Calendar Year 2020 Was Terms and Conditions Deviation a Emission Source Source or Deviations? Records non- Method(s)of Control Device Maintained? Determining Comments Description ID Number(s) permit Condition (Yes/No) (Yes/No/NA) compliance Compliance Status Condition Summary issue? Number Yes/No PM limit, Brick Tunnel Kiln& calculated using Dry Limestone K-I &CD-K 2 2.1.A.I(a) process weight. No N/A No Testing,as required. Absorber(DLA) K-2&CD-K2 rate [2D.0515(a)] Brick Tunnel Kiln& K-1 &CD-K1, PM Testing 2D.0501(c)(3)and Emission testing was not required DLA K-2&CD-K2 2.1.A.I(b) Requirements. No Yes No General Condition JJ. during the reporting period. [2D.0501(c)(3)] Semi-annual inspections (emissions The facility conducts Brick Tunnel Kiln& K-I &CD-K 1, the required DLA K-2&CD-K2 2.1.A.I(c) ductwork and No Yes No inspections semi- fuel combustion system). annually. [2D.0508(f)] Maintain a log Maintain inspection Brick Tunnel Kiln& K-1 &CD-K1, of semi-annual logs with all required 2.1.A.1(d) No Yes No information including Logs contain all required information. DLA K-2&CD-K2 inspections. [2D.0508(f)] date,time,and results of each inspection. Submit semi- annual summary Submission of Brick Tunnel Kiln& K-1 &CD-K1, reports of semiannual inspection Inspections were performed 2.I.A.1(e) No Yes No semiannually as required and records DLA K-2&CD-K2semiannual report to DAQ by were maintained. inspections. reporting date. [2D.0508(f)] Page 2 of 29 North Carolina Department of Environmental Quality Division of Air Quality COMPLIANCE SUMMARY REPORT For Calendar Year 2020 Was Terms and Conditions Deviation a Source or Records Method(s)of Emission Source Control Device Deviations? Maintained? non- Determining Comments Description ID Number(s) Permit Condition (Yes/No) (Yes/No/NA) compliance Compliance Status Condition Summary issue? Number Yes/No Brick Tunnel Kiln& K-1 &CD-K1, S02 Limit,2.3 DLA K-2&CD-K2 2.1.A.2 a lb/MMBtu. No N/A No Testing ,as required. [2D.0516(a)] Brick Tunnel Kiln& K-1 &CD-K1, S02 Testing 213.0501(c)(4)and Emissions testing was not required DLA K-2&CD-K2 2.1.A.2(b) Requirements. No Yes No General Condition JJ. during the reporting period. [213.0501(c)(4)] No Monitoring Brick Tunnel Kiln& K-1 &CD-K1, or Monitoring or recordkeeping is not DLA K-2&CD-K2 2.1.A.2(c) Recordkeeping. No N/A No N/A required when firing natural gas or No.2 fuel oil. [2D.0508(f)] 216 burners maximum Brick Tunnel Kiln& K-1 &CD-K1, allowable fired No.6 fuel oil was not fired during the DLA K-2&CD-K2 2.1.A.2(d) with No.6 Fuel No Yes No N/A reporting period. Oil(FO). [2D.0508(f)] Sulfur in No.6 FO not to FO supplier Brick Tunnel Kiln& K-1 &CD-K1, o certifications are No. 6 fuel oil shipments were not DLA K-2&CD-K2 2.1.A.2(e) exceed 2.1/o by No Yes No weight. maintained per received during the reporting period. [2D.0508(f)] shipment. FO certifications and fuel records FO supplier Brick Tunnel Kiln& K-1 &CD-K1, certifications are No.6 fuel oil shipments were not DLA K-2&CD-K2 2.1.A.2(f) log,updated No Yes No maintained per received during the reporting period. quarterly. [2D.0508(f)] shipment. i Page 3 of 29 North Carolina Department of Environmental Quality Division of Air Quality COMPLIANCE SUMMARY REPORT For Calendar Year 2020 Was Terms and Conditions Deviation a Source or Records Method(s)of Emission Source Deviations? non- Control Device Maintained? Determining Comments Description ID Number(s) Permit Condition (Yes/No) (Yes/No/NA) compliance Compliance Status Condition Summary issue? Number Yes/No SOZ Emissions Semi-annual All monitoring and record keeping Brick Tunnel Kiln& K-1 &CD-K1, Reporting monitoring and record requirements were met during the 2.1.A.2(g) Requirements. No Yes No keeping summary DLA K-2&CD-K2 reporting period and no deviations [2Q.0508(f)] report turned into were reported. DAQ. Opacity<20% based on a 6- *6-min avg.periods may exceed 20% minute avg Monthly observation opacity if. (1)no 6-min period>87% Brick Tunnel Kiln& K-1 &CD-K1, No N/A No*(See more for any visible opacity;(2)no more than 1—6-min DLA K-2&CD-K2 2.1.A.3(a) detail in emissions above period>20%opacity in 1 hour;&(3) Comment normal. no more than 4—6-min periods>20% column). opacity in 24 hrs. [2D.0521(d)] Brick Tunnel Kiln& K-1 &CD-K1, Opacity Testing 2D.0501(c)8)and Emissions testing was not required DLA K-2&CD-K2 2.1.A.3(b) Requirements. No Yes No General Condition JJ. during the reporting period. [213.0501(c)(8)] Opacity Take and record Visible emissions observations were Brick Tunnel Kiln& K-1 &CD-K1, Monitoring monthly observation conducted monthly as required and DLA K-2&CD-K2 2.1.A.3(c) Requirements. No Yes No for any visible visible emissions were not observed [2D.0508(f)] emissions above above normal. normal. Opacity Maintain log Brick Tunnel Kiln& K-1 &CD-K1, Recordkeeping including date,time, 2.1.A.3(d) No Yes No Logs contain all required information. DLA K-2&CD-K2 Requirements. results and corrective [2Q.0508(f)] action if necessary. Page 4 of 29 North Carolina Department of Environmental Quality Division of Air Quality COMPLIANCE SUMMARY REPORT For Calendar Year 2020 Was Terms and Conditions Deviation a Source or Records Method(s)of Emission Source Deviations? non- Description Control Device permit (Yes/No) Maintained? compliance Determining Comments ID Number(s) Condition (Yes/No/NA) Compliance Status Condition Summary issue? Number Yes/No Opacity Visible emissions observations were Brick Tunnel Kiln& K-1 &CD-K1, Reporting Semi-annual opacity conducted monthly as required and DLA K-2&CD-K2 2.1.A.3(e) Requirements. No Yes No summary report visible emissions were not observed [2Q.0508(f)] submitted to DAQ. above normal. < 10 tons per Compliance is required to remain a year of each Testing,as required. minor source for hazardous air and<25 Operate DLAs as Brick Tunnel Kiln& K-1 &CD-K1, HAP, pollutants and avoid 15A NCAC 2.LA.4(a) tons per year of No N/A No required.Calculate DLA K-2&CD-K2 02D.1111:Maximum Achievable all HAPs Emissions from c Control Technology.Emission combined. production rates. [2Q.0317] calculations attached. Brick Tunnel Kiln& K-1 &CD-K1, HAP Testing Emissions testing was not required DLA K-2&CD-K2 2.LA.4(b) Requirements. No N/A No Testing,as required. during the reporting period. [2D.1111] Operate DLAs at all times when Maintain records of Exceptions during periods of startup, Brick Tunnel Kiln& K-1 &CD-K1' shutdown or malfunction or during 2.LA.4(c) the Kilns are No Yes No operating time and ' DLA K-2&CD-K2 operation in bypass mode for routine operational. down time. [2Q.0508(f)] maintenance of the DLAs. Monitor amount of limestone in Maintain daily log Brick Tunnel Kiln& K-1 &CD-K1, limestone verifying limestone DLA K-2&CD-K2 2.1.A.4(d) hopper,storage No Yes No hopper and storage Logs contain all required information. bins,and DLAs. bin DLAs. [.0508(f)] Page 5 of 29 North Carolina Department of Environmental Quality Division of Air Quality COMPLIANCE SUMMARY REPORT For Calendar Year 2020 Was Terms and Conditions Deviation a Source or Records Method(s)of Emission Source Deviations? non- Description Control Device permit (Yes/No) Maintained? compliance Determining Comments ID Number(s) Condition (Yes/No/NA) Compliance Status Condition Summary issue? Number Yes/No Use same grade Brick Tunnel Kiln& K-1 &CD-K1, of limestone Maintain records of DLA K-2&CD-K2 2.LAA(e) used during No Yes No source and grade of Logs contain all required information. performance limestone used. test. [.0508(f)] Maintain limestone feeder Brick Tunnel Kiln& K-1 &CD-K1, setting as DLA Maintain daily log of DLA K-2&CD-K2 2.1.A.4(f) consistent with No Yes No limestone feeder Logs contain all required information. performance settings. test. [.0508(f)] Ensure limestone feed system on DLAs replaces Maintain log of Brick Tunnel Kiln& K-1 &CD-K1, limestone as monthly check of DLA K-2&CD-K2 2.1.A.4(g) frequently as the No Yes No limestone feed Logs contain all required information. schedule set system. during performance test. [.0508(f)] Page 6 of 29 North Carolina Department of Environmental Quality Division of Air Quality COMPLIANCE SUMMARY REPORT For Calendar Year 2020 Was Terms and Conditions Deviation a Source or Records Method(s)of Emission Source Deviations? non- Control Device Maintained? Determining Comments Description ID Number(s) Permit Condition (Yes/No) (Yes/No/NA) compliance Compliance Status Condition Summary issue? Number Yes/No Secure the Monitor damper bypass damper position daily;if lock Bypass Damper Position Report in closed and has been broken or Attached.Damper was closed and Brick Tunnel Kiln& K-1 &CD-K1, locked position. No Yes No damper position has locked for the entire reporting period. DLA K-2&CD-K2 2.1.A.4(h) Monitor the changed monitor and Kiln 2 was shut down on 10 April bypass damper record damper 2020 and the damper records were position. position every 15 discontinued after this date. [.0508(f)] minutes. Records of times Maintain records of Bypass Damper Position Report in which DLA each period in which Attached.Kilns were not operated in Brick Tunnel Kiln& K-1 &CD-K1, bypassed for No Yes No the large tunnel kilns bypass mode during the reporting DLA K-2&CD-K2 2.1.A.4(i) maintenance. operate while period.Kiln 2 was shut down on 10 [2Q.0508(f)] bypassing the DLAs April 2020 and the damper records for maintenance. were discontinued after this date. Records of times Maintain records of in which DLA each period in which bypassed for the large tunnel kilns Bypass Damper Position Report Brick Tunnel Kiln& K-1 &CD-K1, Attached.Kiln 2 was shut down on 10 2.1.A.40) startup, No Yes No operate while DLA K-2&CD-K2 s April 2020 and the damper records shutdown,or bypassing the DLAs were discontinued after this date. malfunction. for startup,shutdown, [2Q.0508(f)] I I or malfunction. Page 7 of 29 North Carolina Department of Environmental Quality Division of Air Quality COMPLIANCE SUMMARY REPORT For Calendar Year 2020 Was Terms and Conditions Deviation a Source or Records Method(s)of Emission Source Deviations? non- Control Device Maintained? Determining Comments Description ID Number(s) Permit Condition (Yes/No) (Yes/No/NA) compliance Compliance Status Condition Summary issue? Number es/No Maintain records of production rates Maintain log of Brick Tunnel Kiln& K-1 &CD-Kl, on fired-product production rates on Logs contain all required information DLA K-2&CD-K2 2.LAA(k) basis and No Yes No fired-product basis and HAP emissions. estimate HAP and estimate HAP emissions. emissions. [2Q.0508(f)] Maintain Brick Tunnel Kiln& K-1 &CD-Kl, records of Maintain applicability Applicability determination kept on DLA K-2&CD-K2 2.LAA(1) applicability No Yes No determination on site. site. determination. [2Q.0508(f)] Semi-annual report of Semi-annual monitoring and Brick Tunnel Kiln& K-1 &CD-K1, recordkeeping monitoring and Bypass Damper Position Report and DLA K-2&CD-K2 2.1.A.4(m) activities No Yes No recordkeeping HAP emissions report attached. 2.LAA(b) summary report through(1). submitted to DAQ. [2Q.0508(f)] S02 Limit,2.3 Rotary Coatings Dryer SD-1 2.1.B.1(a) lb/MMBtu. No N/A No Testing,if required. Emissions testing was not required during the reporting period. [2D.0516(a)] S02 Testing Rotary Coatings Dryer SD-1 2.1.B.1(b) Requirements. No Yes No 2D.0501(c)(4)and Emissions testing was not required [2D.0501(c)(4)] General Condition JJ. during the reporting period. Page 8 of 29 North Carolina Department of Environmental Quality Division of Air Quality COMPLIANCE SUMMARY REPORT For Calendar Year 2020 Was Terms and Conditions Deviation a Source or Records Method(s)of Emission Source Deviations? non- Description Control Device permit (Yes/No) Maintained? compliance Determining Comments ID Number(s) Condition (Yes/No/NA) Compliance Status Condition Summary issue? Number Yes/No No Monitoring Rotary Coatings Dryer SD-1 2.1.B.1(c) or No N/A No N/A Monitoring and recordkeeping are Recordkeeping. not required when firing natural gas. [2D.0508(f)] General Rotary Coatings Dryer SD-1 2.1.B.2(a) compliance No N/A No N/A statement. [2Q.0508(f)] Dryers PM limit, 0.057 g/dscm; Rota Coatings Dryer SD-1 2.1.B.2 b 10%Opacity. No N/A No Testing,as required. Emissions testing was not required Rotary g ry ( ) p ty g' q during the reporting period. [40 CFR 60.732] The opacity standards of this part do not apply during Opacity standards set forth in this part Rotary Coatings Dryer SD-1 2.1.13.2(c) periods of No N/A No apply at all times except during startup, periods of startup,shutdown,or shutdown,or malfunction. malfunction. [60.11(c)] Page 9 of 29 North Carolina Department of Environmental Quality Division of Air Quality COMPLIANCE SUMMARY REPORT For Calendar Year 2020 Was Terms and Conditions Deviation a Source or Records Method(s)of Emission Source Deviations? non- Control Device Maintained? Determining Comments Description ID Number(s) Permit Condition (Yes/No) (Yes/No/NA) compliance Compliance Status Condition Summary issue? Number Yes/No Maintain& operate in a Acceptable O&M is manner consistent with based on monitoring good air results,opacity Rotary Coatings Dryer SD-1 2.1.B.2(d) pollution control No N/A No observations,review practices for of maintenance and operating procedures, minimizing and source inspection. emissions. [60.11(d)] Opacity and Visible Fugitive Initial compliance or The facility has demonstrated initial when subsequent compliance and additional emissions Rotary Coatings Dryer SD-1 2.1.B.2(e) Emissions No N/A No additional testing is testing was not required during the Testing. [2D.0501(c)(3)] required. reporting period. Use Accepted Reference Methods& Reference methods& Testing was not required during the Rotary Coatings Dryer SD-1 2.1.B.2(f) Procedures for No N/A No procedures are reporting period.Above normal observations were not observed ruing daily documented. observations. the reporting period. [60.8(b)] Periodic Conduct inspection inspection and and maintenance by At a minimum,the facility conducts Rotary Coatings Dryer SD-1 2.1.B.2(g) No Yes No the required inspections semi- maintenance. recommended [60.732(a)(1) procedures. annually. Page 10 of 29 North Carolina Department of Environmental Quality Division of Air Quality COMPLIANCE SUMMARY REPORT For Calendar Year 2020 Was Terms and Conditions Deviation a Source or Records Method(s)of Emission Source Deviations? non- Description Control Device permit (Yes/No) Maintained? compliance Determining Comments ID Number(s) Condition (Yes/No/NA) Compliance Status Condition Summary issue? Number Yes/No Maintain records of all Maintain records and results of monitoring Rotary Coatings Dryer SD-1 2.1.B.2(h) observations, No Yes No observations, Testing required during the reporting inspections,and inspections,and period. maintenance. maintenance in logs on-site. [2Q.0508(f)] Retain records for at Records are retained for at least 5 in Rotary Coatings Dryer SD-1 2.I.B.2(i) No Yes No electronic least 5 years rs years in electronic or hardcopy for 5 years.Retain records or hardco y format. format. Summary Reports of Semi-annual summary Inspections were conducted and logs inspection and Reports of inspection maintained during reporting period. Rotary Coatings Dryer SD-1 2.1.B.20) No Yes No maintenance and maintenance Performance testing was not required activities. activities. during this period. [2Q.0508(f)] Maintain opacity log Opacity and visible observer Triangle Brick maintains records Recordkeeping emission certifications . Rotary Coatings Dryer SD-1 2.1.B.2(k) Requirements. No Yes No and make available including the visible emission observer certification. [2Q.0508(f)] upon request by DAQ. Notifications for re-construction Referenced Rotary Coatings Dryer SD-1 2.1.B.2(1) and initial No Yes No notifications are Notifications were not required startup. [60.7& made,as required. during the reporting period. 60.15] Page 11 of 29 North Carolina Department of Environmental Quality Division of Air Quality COMPLIANCE SUMMARY REPORT For Calendar Year 2020 Was Source or Terms and Conditions Records Deviation a Method(s)of Emission Source Deviations? non- Control Device Maintained? Determining Comments Description ID Number(s) Permit Condition (Yes/No) (Yes/No/NA) compliance Compliance Status Condition Summary issue? Number Yes/No Environmental See applicable Management provisions, The facility complies with all Commission notifications,testing, Scalp screens,jaw PC-3 to PC-10 2.1.C.1(a) NSPS Standard. No Yes No reporting, requirements promulgated in 40 CFR crushers,&conveyors 60.670,Subpart 000,including [2D.0524& recordkeeping and Subpart A"General Provisions". NSPS Subpart monitoring 000] requirements. Opacity<10%. Monthly observation Monthly visible observations in Scalp screens,jaw PC-3,4,7,8, 2.1.C.1(b) [40 CFR 60.672 No N/A No for any visible excess of normal were not observed crushers,&conveyors and 9 emissions above (b),(c)&(e)] during the reporting period. normal. Opacity<15% Monthly observation Monthly visible observations in Scalp screens,jaw PC-5&PC-6 2.1.C.1(b) [40 CFR. No N/A No for any visible excess of normal were not observed crushers,&conveyors 60.672(c)] emissions above during the reporting period. normal. Opacity<7%for building Monthly observation Monthly visible observations in Scalp screens,jaw for any visible PC-10 2.1.C.1(b) openings. No N/A No excess of normal were not observed crushers,&conveyors [40 CFR emissions above during the reporting period. 60.672(e)] normal. r Page 12 of 29 North Carolina Department of Environmental Quality Division of Air Quality COMPLIANCE SUMMARY REPORT For Calendar Year 2020 Was Terms and Conditions Deviation a Source or Records Method(s)of Emission Source Deviations? non- Description Control Device permit (Yes/No) Maintained? compliance Determining Comments ID Number(s) Condition (Yes/No/NA) Compliance Status Condition Summary issue? Number Yes/No Maintain& operate in a manner consistent with Opacity standards set forth in this part Scalp screens,jaw good air apply at all times except during crushers,&conveyors PC-3 to PC-10 2.1.C.1(c) pollution control periods of startup,shutdown,or practices for malfunction. minimizing emissions. [60.11(c)] Maintain& operate in a Acceptable O&M is manner consistent with based on monitoring Scalp screens,jaw good air results,opacity crushers,&conveyors PC-3 to PC-10 2.1.C.1(d) pollution control No Yes No observations,review of maintenance and practices for operating procedures, minimizing emissions. and source inspection. [60.11(d)] Opacity and Visible Fugitive Initial compliance or The facility has demonstrated initial Scalp screens,jaw when subsequent compliance and additional emission PC-3 to PC-10 2.1.C.1(e) Emissions No Yes No crushers,&conveyors additional testing is testing was not required during the Testing. [2Q .shin required. reporting period. Page 13 of 29 North Carolina Department of Environmental Quality Division of Air Quality COMPLIANCE SUMMARY REPORT For Calendar Year 2020 Was Terms and Conditions Deviation a Source or Records Method(s)of Emission Source Deviations? non- Description Control Device permit (Yes/No) Maintained? compliance Determining Comments ID Number(s) Condition (Yes/No/NA) Compliance Status Condition Summary issue? Number Yes/No Observe fugitive Complete visible Scalp screens,jaw emissions fugitive emission Visible emissions observations were PC-3 to PC-10 2.1.C.1(f) monthly. No Yes No � crushers,&conveyors [40 CFR 60.674, observation logs are conducted monthly as required. 2Q.0508(f)] maintained on-site. Reestablishing Reestablishing normal Reestablishing normal visible Scalp screens,jaw normal visible visible emissions by crushers,&conveyors PC-3 to PC-10 2.1.C.1(g) emission levels. observing each week emissions was not required during the reporting period. [2D.0524] for 30 days. Maintain a complete log of Scalp screens,jaw Complete opacity log crushers,&conveyors PC-3 to PC-10 2.1.C.1(h) opacity No Yes No is maintained. Logs contain all required information. observations. [2D.0508(f)] Monthly Visible emissions observations were observations of conducted monthly as required. visible Complete visible Visible emissions above normal were Scalp screens,jaw crushers,&conveyors PC-3 to PC-10 2.1.C.1(i) emissions,do No Yes No emission observation not observed during the reporting Method 9 if log is maintained. period.Changes were not made at the above normal. existing facilities during the reporting [2D.0508(f)] period. Page 14 of 29 North Carolina Department of Environmental Quality Division of Air Quality COMPLIANCE SUMMARY REPORT For Calendar Year 2020 Was Terms and Conditions Deviation a Source or Records Method(s)of Emission Source Deviations? non- Description Control Device permit (Yes/No) Maintained? compliance Determining Comments ID Number(s) Condition (Yes/No/NA) Compliance Status Condition Summary issue? Number Yes/No Environmental See applicable Management provisions, The facility complies with all Clay Grinding Plant& Commission notifications,testing, Associated CG-2 to CG-8 2.1.D.1(a) NSPS Standard. No Yes No reporting, requirements promulgated in 40 CFR Conveyances CG-10 to CF-28 [2D.0524& recordkeeping and 60.670,Subpart 000,including Subpart A"General Provisions". NSPS Subpart monitoring 000] requirements. Opacity<7%for Clay Grinding Plant& building Monthly observation Monthly visible observations in Associated C - to CG-8 2.1.D.1(b) openings. No N/A No for any visible excess of normal were not observed Conveyances CG10 to CF-28 [40 CFR emissions above normal. during the reporting period. 60.672(e)] Opacity standards set forth in this requirement Clay Grinding Plant& apply at all Opacity standards set forth in this part CG-2 to CG-8 apply at all times except during Associated CG-10 to CF-28 2.1.D.1(c) times except No N/A No periods of startup,shutdown,or Conveyances during periods of startup, malfunction. shutdown,or malfunction. [60.11(c)] Page 15 of 29 North Carolina Department of Environmental Quality Division of Air Quality COMPLIANCE SUMMARY REPORT For Calendar Year 2020 Was Terms and Conditions Deviation a Source or Records Method(s)of Emission Source Deviations? non- Control Device Maintained? Determining Comments Description ID Number(s) Permit Condition (Yes/No) (Yes/No/NA) compliance Compliance Status Condition Summary issue? Number Yes/No Maintain& operate in a Acceptable O&M is manner consistent with based on monitoring Clay Grinding Plant& results,opacity CG-2 to CG-8 Associated CG-10 to CF-28 2.1.D.1(d) good air pollution control No Yes No observations,review Conveyances of maintenance and practices for minimizing operating procedures, and source inspection. emissions. [60.11(d)] Opacity and Initial compliance or The facility has demonstrated initial Clay Grinding Plant& CG-2 to CG-8 Visible Fugitive when subsequent compliance and additional emission Associated CG-10 to CF-28 2.1.D.I(e) Emissions. No Yes No additional testing is testing was not required during the Conveyances Testing[2Q .0508(f)] required. reporting period. Observe fugitive Complete visible Clay Grinding Plant& CG-2 to CG-8 emissions fugitive emission Visible emissions observations were Associated 2.1.D.1(f) monthly. No Yes No Conveyances CG-10 to CF-28 [40 CFR 60.674, observation logs are conducted monthly as required. 2Q.0508(f)] maintained on-site. Reestablishing Reestablishing normal Clay Grinding Plant& Reestablishing normal visible Associated CG-2 to CG-8 2.1.D.I(g) normal visible No N/A No visible emissions by emissions was not required during the CG-10 to CF-28 emission levels. observing each week Conveyances 2D.0524 for 30 days. reporting period. Page 16 of 29 North Carolina Department of Environmental Quality Division of Air Quality COMPLIANCE SUMMARY REPORT For Calendar Year 2020 Was Terms and Conditions Deviation a Source or Records Method(s)of Emission Source Deviations? non- Control Device Maintained? Determining Comments Description ID Number(s) Permit Condition (Yes/No) (Yes/No/NA) compliance Compliance Status Condition Summary issue? Number Yes/No Summary All monitoring and record keeping Semi-annual Reporting requirements were met and no Clay Grinding Plant& CG-2 to CG-8 Requirements. monitoring and record deviations were observed.Changes Associated CG-10 to CF-28 2.1.D.1(h) [2Q 0508(f)] No Yes No keeping summary have were not made at any of the Conveyances report turned into DAQ. existing facilities during the reporting period. Environmental See applicable Management provisions, The facility complies with all Loam/Sawdust Commission notifications,testing, requirements promulgated in 40 CFR Preparation Area& LS-2 to LS-12 2.1.E.1(a) NSPS Standard. No Yes No reporting, 60.670,Subpart 000,including Assoc.Conveyances [213.0524& recordkeeping and Subpart A"General Provisions". NSPS Subpart monitoring 000] requirements. Opacity<7%for Monthly observation Loam/Sawdust building for any visible Monthly visible observations in Preparation Area& LS-2 to LS-12 2.1.E.1(b) openings. No N/A No emissions above excess of normal were not observed Assoc.Conveyances [40 CFR during the reporting period. 60.672(e)] normal. Page 17 of 29 North Carolina Department of Environmental Quality Division of Air Quality COMPLIANCE SUMMARY REPORT For Calendar Year 2020 Was Terms and Conditions Deviation a Source or Records Method(s)of Emission Source Deviations? non- Description Control Device permit (Yes/No) Maintained? compliance Determining Comments ID Number(s) Condition (Yes/No/NA) Compliance Status Condition Summary issue? Number Yes/No Opacity standards set forth in this requirement Loam/Sawdust apply at all Opacity standards set forth in this part apply at all times except during Preparation Area& LS-2 to LS-12 2.1.E.I(c) times except No N/A No periods of startup,shutdown,or Assoc.Conveyances during periods malfunction of startup, shutdown,or malfunction. [60.11(c)] Maintain& operate in a Acceptable O&M is manner consistent with based on monitoring Loam/Sawdust results,opacity Preparation Area& LS-2 to LS-12 2.1.E.I(d) good airpollution control No Yes No observations,review Assoc.Conveyances of maintenance and practices for operating procedures, minimizing and source inspection. emissions. [60.11(d)] Opacity and Loam/Sawdust Visible Fugitive Initial compliance or The facility has demonstrated initial when subsequent compliance and additional emission Preparation Area& LS-2 to LS-12 2.1.E.1(e) Emissions No Yes No additional testing is testing was not required during the Assoc.Conveyances Testing. [2Q .0508(f)] required. reporting period. Page 18 of 29 North Carolina Department of Environmental Quality Division of Air Quality COMPLIANCE SUMMARY REPORT For Calendar Year 2020 Was Terms and Conditions Deviation a Source or Records Method(s)of Emission Source Deviations? non- Description Control Device permit (Yes/No) Maintained? compliance Determining Comments ID Number(s) Condition (Yes/No/NA) Compliance Status Condition Summary issue? Number Yes/No Observe fugitive Loam/Sawdust emissions Complete visible Preparation Area& LS-2 to LS-12 2.1.E.1(f) monthly. No Yes No fugitive emission Visible emissions observations were Assoc.Conveyances [40 CFR 60.674, observation logs are conducted monthly as required. 2Q.0508(f)] maintained on-site. Loam/+A 127:B l3l Saw Reestablishing Reestablishing normal Reestablishing normal visible dust Preparation Area LS-2 to LS-12 2.1.E.1(g) nor emissions was not required during the emi mal visible visible emissions by ssion levels. observing each week &Assoc.Conveyances 2D.0524 for 30 days. reporting period. Summary Semi-annual All monitoring and record keeping Reporting requirements were met and deviations Secondary Clay CG-30 thru CG- Requirements. monitoring and record were not observed during the Grinding Plant& 55 2.1.E.1(h) [2Q 0508(f)] No Yes No keeping summary reporting period.Changes have not Assoc.Conveyances report turned into DAQ. been made at any of the existing facilities during the reporting period. Environmental See applicable Management provisions, Secondary Clay Commission notifications, , The facility complies with all CG-30 thru CG- testing, promulgated in 40 CFR Grinding Plant& 2.1.F.1(a) NSPS Standard. No Yes No reporting, Assoc.Conveyances 55 [2D.0524& recordkeeping and 60.670,Subpart 000,including Subpart A"General Provisions". NSPS Subpart monitoring 000] requirements. Opacity<7%for Monthly observation Secondary Clay building Monthly visible observations in 555 emissions above Grinding Plant& CG-30 t CG- 2.1.F.1(b) openings. No N/A No for any visible excess of normal were not observed Assoc.Conveyances [40 CFR during the reporting period. 60.672(e)] normal. Page 19 of 29 North Carolina Department of Environmental Quality Division of Air Quality COMPLIANCE SUMMARY REPORT For Calendar Year 2020 Was Terms and Conditions Deviation a Emission Source Source or Deviations? Records non- Method(s)of Description Control Device permit (Yes/No) Maintained? compliance Determining Comments ID Number(s) Condition (Yes/No/NA) Compliance Status Condition Summary issue? Number Yes/No Opacity standards set forth in this requirement Secondary Clay apply at all Opacity standards set forth in this part Grinding Plant& CG-30 thru CG- 2.l.F.1(c) times except No N/A No apply at all times except during 55 periods of startup,shutdown,or Assoc.Conveyances during periods malfunction. of startup, shutdown,or malfunction. [60.11(c)] Maintain& operate in a Acceptable O&M is manner consistent with based on monitoring Secondary Clay results,opacity CG-30 thru CG- good air Grinding Plant& 55 2.1.F.1(d) pollution control No Yes No observations,review Assoc.Conveyances of maintenance and practices for operating procedures, minimizing emissions. and source inspection. [60.11(d)] Opacity and Secondary Clay Visible Fugitive Initial compliance or The facility has demonstrated initial CG-30 thru CG- when subsequent compliance and additional emissions Grinding Plant& 2.1.F.1(e) Emissions No Yes No 55 additional testing is testing was not required during the Assoc.Conveyances Testing. [2Q .0508(f)] required. reporting period. i Page 20 of 29 North Carolina Department of Environmental Quality Division of Air Quality COMPLIANCE SUMMARY REPORT For Calendar Year 2020 Was Terms and Conditions Deviation a Source or Records Method(s)of Emission Source Deviations? non- Description Control Device permit (Yes/No) Maintained? compliance Determining Comments ID Number(s) Condition (Yes/NO/NA) Compliance Status Condition Summary issue? Number Yes/No Observe fugitive Secondary Clay emissions Complete visible Grinding Plant& CG-30 thru CG- 2.1.F.1(f) monthly. No Yes No fugitive emission Visible emissions observations were Assoc.Conveyances 55 [40 CFR 60.674, observation logs are conducted monthly as required. maintained on-site. 2Q.0508(f)] Reestablishing Reestablishing normal Secondary Clay Reestablishing normal visible Grinding Plant& CG-30 thru CG- 2 1.F.1(g) normal visible No N/A No visible emissions by emissions was not required during the 55 emission levels. observing each week Assoc.Conveyances [2D.0524 for 30 days. reporting period. Summary All monitoring and record keeping Semi-annual Reporting requirements were met and Secondary Clay CG-30 thru CG- monitoring and record Grinding Plant& 2.1.F.I(h) Requirements. No Yes No keeping summary deviations were not observed during Assoc.Conveyances 55 [2Q.0508(f)] report turned into the reporting period.Changes have DAQ. not been made at any of the existing facilities during the reporting period. Odorous Implementing Objectionable odors were not Facility All 2.2.A.1(a) emissions must No Yes No management practices detected beyond the facility boundary be controlled. or operating odor [213.1806 control equipment. during the reporting period. Maximum feasible odor controls if Objectionable odors were not Facility All 2.2.A.1(b) determined to No N/A No N/A detected beyond the facility boundary have during the reporting period. objectionable. odor. [21).1806] Page 21 of 29 North Carolina Department of Environmental Quality Division of Air Quality COMPLIANCE SUMMARY REPORT For Calendar Year 2020 Was Terms and Conditions Deviation a Source or Records Method(s)of Emission Source Deviations? non- Description Control Device permit (Yes/No) Maintained? compliance Determining Comments ID Number(s) Condition (Yes/No/NA) Compliance Status Condition Summary issue? Number Yes/No Toxic Air Pollutants Facility is operated (TAPs)from and maintained to Brick Tunnel Kilns K-1 &K-2 2.2.A.2(a) facility not to No Yes No exceed keep actual emissions emission.limit below emission limit. [2D.1100] Maximum of 58,000 lbs of clay brick and Maintain production Records were maintained for the kilns Brick Tunnel Kilns K-1 &K-2 2.2.A.2(b) additives No Yes No records to be reported and submitted quarterly. processed per semiannually. hour per kiln. [213.0611] Maintain records of production rates Records maintained Records are retained for at least 3 Brick Tunnel Kilns K-1 &K-2 2.2.A.2(c) No Yes No years in electronic or hardcopy throughputs,& on-site for three years. format. material usages. [2D.1100] Page 22 of 29 North Carolina Department of Environmental Quality Division of Air Quality COMPLIANCE SUMMARY REPORT For Calendar Year 2020 Was Terms and Conditions Deviation a Emission Source Source or Deviations? Records non- Method(s)of Control Device Maintained? Determining Comments Description Permit compliance ID Number(s) (Yes/No)Condition (Yes/No/NA) Compliance Status Condition Summary issue? Number Yes/No DAQ has right to sample/analyze Brick Tunnel Kilns K-1 &K-2 2.2.A.2(d) clay&shales for No N/A No N/A hydrogen fluoride(HF) concentration. [2D.1100] Notify DAQ within 30 days of startup of use Notifications are No new source of clay during the Brick Tunnel Kilns K-1 &K-2 2.2.A.2(e) of any clay for No Yes No maintained on-site. reporting period. HF concentration. [2D.1100] Notify of new source of clay or Notifications are additives and made with in 30 days Brick Tunnel Kilns K-1 &K-2 2.2.A.2(f) provide No Yes No and results submitted No new source of supplies. analytical results with in 30 days of of HF. new source. [2D.11001 Page 23 of 29 North Carolina Department of Environmental Quality Division of Air Quality COMPLIANCE SUMMARY REPORT For Calendar Year 2020 Was Terms and Conditions Deviation a Source or Records Method(s)of Emission Source Deviations? non- Description Control Device permit (Yes/No) Maintained? compliance Determining Comments ID Number(s) Condition Condition (Yes/No/NA) issue? Compliance Status Number Summary Yes/No Semi-annual All monitoring and record keeping requirements were met and deviations summary report Semi-annual summary of monitoring report of monitoring were not observed during the reporting period.Quarterly reports Brick Tunnel Kilns K-1 &K-2 2.2.A.2(g) and record No Yes No and record keeping keeping activities turned into showing maximum amount of materials processed per hour have activities. DAQ. [2D.0611] been submitted on a timely basis during the reporting period. Toxic Air Pollutants (TAPs)from facility not to Facility is operated exceed Toxic and maintained to Facility All 2.2.A.3(a) permit Emission No Yes No keep actual emissions <TPERs for each of Rates(TPERs) for listed the listed pollutants. pollutants. [2Q.0711] S02 limited to 250 tons per Facility-wide S02 The K-1 S02 emissions did not emissions are Brick Tunnel Kiln K-1 2.2.B.l(a) consecutive 12- No Yes No maintained monthly exceed 250 tpy during the reporting month period. period. [2D.0530(g)] in a spreadsheet. Page 24 of 29 North Carolina Department of Environmental Quality Division of Air Quality COMPLIANCE SUMMARY REPORT For Calendar Year 2020 Was Terms and Conditions Deviation a Source or Records Method(s)of Emission Source Deviations? non- Control Device Maintained? Determining Comments Description ID Number(s) Permit Condition (Yes/No) (Yes/No/NA) compliance Compliance Status Condition Summary issue? Number Yes/No Limits:920,000 gal/yr of No.6 Brick Tunnel Kiln K-1 2.2.B.1(b) FO;2.1%S02 No Yes No Monthly records are by wt;58,000 maintained on-site. lb/hr production. S02 Testing Brick Tunnel Kiln K-1 2.2.B.1(c) Requirements. No N/A No 2D.0501(c)(4)and Emissions testing was not required [2D.0501(c)(4)] General Condition JJ. during the reporting period. Maintain monthly records, Monthly records are Brick Tunnel Kiln K-1 2.2.B.1(d) including fuel No Yes No certification. maintained in a log. [2Q.0508(f)] Calculate and record S02 Facility-wide S02 emission logs, monthly emissions Records are retained for at least 5 Brick Tunnel Kiln K-1 2.2.B.1(e) available for 5 No Yes No spreadsheets are years in electronic or hardcopy maintained for 5 format. years. [2Q.0508(f)] years. Submit S02 reports within Submission of 30 days after No Yes No semiannual S02 Triangle Brick submitted quarterly Brick Tunnel Kiln K-1 2.2.B.1(f) each calendar report to DAQ by reports during the reporting period. quarter. reporting date. [2Q.0508(f)] Page 25 of 29 North Carolina Department of Environmental Quality Division of Air Quality COMPLIANCE SUMMARY REPORT For Calendar Year 2020 Was Terms and Conditions Deviation a Source or Records Method(s)of Emission Source Deviations? non- Description Control Device permit (Yes/No) Maintained? compliance Determining Comments ID Number(s) Condition Condition (Yes/No/NA) issue? Compliance Status Summary Number Yes/No S02 limited to Facility-wide S02 250 tons per emissions are K-2's S02 emissions did not exceed Brick Tunnel Kiln K-2 2.2.C.1(a) consecutive 12- No Yes No month period. maintained monthly in 250 tpy during the reporting period. [2D.0530(g)] a spreadsheet. S02 Testing 2D.0501(c)(4)and Emissions testing was not required Brick Tunnel Kiln K-2 2.2.C.1(b) Requirements No N/A No General Condition JJ. during the reporting period. [2D.0501(c)(4)] Maintain monthly records of amount of Monthly records are Brick Tunnel Kiln K-2 2.2.C.1(c) fuel used,sulfur No Yes No maintained in a log. content,&fuel certification. [2Q.0508(f)] Maintain Facility-wide S02 monthly records nth monthly emissions Records are retained for at least 5 Brick Tunnel Kiln K-2 2.2.C.1(d) Of S02No Yes No spreadsheets are years in electronic or hardcopy emissions in a maintained for 5 format. logbook. [2D.0530] years. Page 26 of 29 North Carolina Department of Environmental Quality Division of Air Quality COMPLIANCE SUMMARY REPORT For Calendar Year 2020 Was Terms and Conditions Deviation a Source or Records Method(s)of Emission Source Control Device IDeviations? non- Maintained? Determining Comments Description ID Number(s) Permit Condition (Yes/No) (Yes/No/NA) compliance Compliance Status Condition Summary issue? Number Yes/No Submit semiannual summary reports of monthly S02 Submission of semiannual S02 Triangle Brick submitted quarterly Brick Tunnel Kiln K-2 2.2.C.1(e) emissions& No Yes No report to DAQ by reports during the reporting period. monthly quantities of reporting date. natural gas. [2Q.0508(f)] Revision 3.0 Page 27 of 29 North Carolina Department of Environmental Quality Division of Air Quality DEVIATION SUMMARY REPORT For Calendar Year 2020 Source or Control Emission Source Deviation Deviation Suspected Cause of Description Device ID Pollutant Description Date(s) Deviation Deviation Duration Corrective Action Taken Number(s) Deviations were not observed during the reporting period. Revision 3.0 Page 28 of 29 North Carolina Department of Environmental Quality Division of Air Quality COMPLIANCE SUMMARY REPORT FOR GENERAL CONDITIONS For Calendar Year 2020 Terms and Conditions Deviations? Records Maintained? Was Deviation a non- Method(s)of Permit Condition (Yes/No/NA) compliance issue?(Yes/ Determining Comments Number Condition Summary (Yes/No) No) Compliance Status 3.A General provisions No Yes No N/A 3.13 Permit available at facility No Yes No Permit kept on-site. 3.D Submissions of reports to regional office No Yes No Reports sent to Regional Office. Submit permit New permit modification requests were not 3.G Permit modifications and applications No Yes No applications as submitted during previous reporting period. needed. 3.H Changes not requiring permit modifications No Yes No N/A A report was not required during this reporting Reporting requirements for excess emissions and permit 3.I.A,3.I.B No Yes No Record of report. period,as excess emssions and permit deviations deviations were not observed. 3.K Permit renewal every five year No N/A No Permit expires June 30,2023. 3.M Duty to submit any information requested by director No N/A No N/A 3.N Duty to supplement No N/A No N/A 3.0 Retention of records No Yes No Record kept on-site for 5 years. Submit annual 3.P Annual compliance certification No Yes No compliance Submitted early with semi-annual report. certification by March 1 each year. 3.Q Certification by responsible official No Yes No Certification ResponsibleOfficial certified report. required. 3.T Insignificant activities records available at facility No Yes No On-site recordkee in . 3.V Inspection and entry No Yes No On-site recordkee in . 3.W Annual fee payment No Yes No On-site Annualfee payment was submitted on time. recordkee in . 3.X Annual emission inventory requirement No Yes No On-site Emissions Inventory was submitted prior to July recordkee in . 31,2020. 3.Y Confidential information No N/A No N/A Page 29 of 29 32 Construction and operation permits No Yes No On-site recordkee in . 3.AA Standard application form and required information No N/A No N/A The Wadesboro facility does not operate any 3.CC Refrigerant requirements No Yes No N/A equipment that contains Class I or Class II refrigerants. 3.DD Prevention of accidental releases—Section 112(r) No Yes No N/A Prevention of accidental releases"General Duty Clause"- Take steps to prevent Triangle Brick is not subject to Risk Management 3.EE No Yes No Program requirements,but does meet with the Section 112(r)(1) accidental releases. general duty clause under this condition. 3.II Ambient air quality standards No Yes No On-site recordkee in . 3.JJ Emission testing and reporting requirements No Yes No On-site Stack testing was not required during this reporting recordkeeping. period. ILL Reporting requirements for non-operating equipment No Yes No On-site recordkee in . 3.MM Fugitive Dust Control Requirement No Yes No Visible Emissions Monitoring. INN Modification of a TV permit No Yes No N/A Modifications were not made at the facility during the reporting eriod. 3.00 Third party participation&EPA review No N/A No N/A Revision 3.0 Attachment 2 Facility-wide Emissions of Hazardous Air Pollutants HAP Report Triangle Brick Company Wadesboro,North Carolina January/2020-June/2020 Month Monthly Monthly Rolling History Rolling History HAP Max lbs HAP total lbs HAP Max lbs HAP total lbs Jan-20 Hydrogen Chloride 109 370 Hydrogen Chloride 1,333 4,513 Feb-20 Hydrogen Chloride 105 354 Hydrogen Chloride 1,333 4,513 Mar-20 Hydrogen Chloride 111 377 Hydrogen Chloride 1,338 4,530 Apr-20 Hydrogen Chloride 95 322 Hydrogen Chloride 1,320 4,468 May-20 Hydrogen Chloride 89 301 Hydrogen Chloride 1,314 4,448 Jun-20 Hydrogen Chloride 89 302 Hydrogen Chloride 1,308 4,426 Triangle Brick started reporting HAP in January 2018. "Rolling History"includes the months since January 2018 for each month reported. In July 2019-"Rolling History"will include 12 months for each month reported. Monday,July 20,2020 HAP Report Triangle Brick Company Wadesboro, North Carolina July/2020-December/2020 Month Monthly Monthly Rolling History Roiling History HAP Max lbs HAP total Ibs HAP Max Ibs HAP total Ibs ................__....._................__..._................... ___ ..........__ Jul-20 Hydrogen Chloride 94 317 Hydrogen Chloride 1,310 4,433 Aug-20 Hydrogen Chloride 95 323 Hydrogen Chloride 1,314 4,445 Sep-20 Hydrogen Chloride 90 304 Hydrogen Chloride 1,294 4,377 Ott-20 Hydrogen Chloride 99 335 Hydrogen Chloride 1,283 4,341 Nov-20 Hydrogen Chloride 90 304 Hydrogen Chloride 1,257 4,253 Dec-20 Hydrogen Chloride 86 289 Hydrogen Chloride 1,248 4,222 Triangle Brick started reporting HAP in January 2018. "Rolling History"includes the months since January 2018 for each month reported. In July 2019-"Rolling History"will include 12 months for each month reported. Monday,January 18,2021 it Attachment 3 Bypass Damper Position Report p ° ~ Associated with the o ration ofthe DLA Limestone Feeder Settin-gs Diff. 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