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Triangle Brick Company,
Wadesboro
Title V Air Permit Renewal Application
November 2022
Project No.: 0655839 RECEIVED
NOV 2 1 22
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The business of sustainability ERR

Signature Page
November 2022
Triangle Brick Company, Wadesboro
Title V Air Permit Renewal Application
Kevin Eldridge
Project Manager
Jeffrey Twaddle, P.E.
Partner
ERM NC, Inc.
©Copyright 2022 by ERM Worldwide Group Ltd and/or its affiliates(`ERM').
All rights reserved.No part of this work may be reproduced or transmitted in any form.
or by any means,without the prior written permission of ERM.
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TRIANGLE BRICK COMPANY,WADESBORO CONTENTS
Title V Air Permit Renewal Application
CONTENTS
1. INTRODUCTION................................................................................................................................1
2. FACILITY DESCRIPTION..................................................................................................................2
2.1 Facility Location....................................................................................................................................4
2.2 Facility Emissions.................................................................................................................................5
3. REGULATORY ANALYSIS ...............................................................................................................7
3.1 Federal Regulatory Applicability...........................................................................................................7
3.1.1 40 CFR 52—Prevention of Significant Deterioration of Air Quality......................................8
3.1.2 40 CFR 60—New Source Performance Standards.............................................................8
3.1.3 40 CFR 61 and 63—National Emission Standards for Hazardous Air Pollutants............ .10
3.1.4 40 CFR 64—Compliance Assurance Monitoring(CAM)....................................................10
3.1.5 40 CFR 68—Chemical Accident Prevention Provisions....................................................11
3.1.6 40 CFR 70—Title V Operating Permit Program.................................................................11
3.1.7 40 CFR 98—Mandatory Greenhouse Gas Reporting........................................................11
3.2 State Regulatory Applicability.............................................................................................................11
New Source Performance Standard Subpart UUU-Standards of Performance for Calciners
and Dryers in Mineral Industries........................................................................................12
3.2.1 15A NCAC 2D.0515-Particulates from Miscellaneous Industrial Processes...................12
3.2.2 15A NCAC 2D.0516-Sulfur Dioxide Control Requirement..............................................13
3.2.3 15A NCAC 2D.0521 -Control of Visible Emissions..........................................................13
3.2.4 15A NCAC 2D.0524-New Source Performance Standards Subpart UUU -
Standards of Performance for Calciners and Dryers in Mineral Industries.........................13
3.2.5 15A NCAC 02D.0900—Volatile Organic Compounds......................................................13
3.2.6 15A NCAC 02D.1100-Toxic Air Pollution Emission Limitations and Reporting
Requirement and 15A NCAC 020 .0700—Toxic Air Pollutant Procedures.......................13
3.2.7 15A NCAC 02D.1111 —Maximum Achievable Control Technology..................................14
3.2.8 15A NCAC 02D.1400-Nitrogen Oxides...........................................................................14
3.2.9 15A NCAC 02D.1806-Control and Prohibition of Odorous Emissions............................14
3.2.10 15A NCAC 02Q.0317-Avoidance of the Applicability of Major Source MACT
Standards..........................................................................................................................14
3.2.11 15A NCAC 02Q.0317-Avoidance Condition for 15A NCAC 2D.0530-Prevention of
Significant Deterioration.....................................................................................................15
3.2.12 15 NCAC 02Q.0500-Title V Procedures.........................................................................15
3.3 General Conditions.............................................................................................................................15
3.3.1 15A NCAC 02D.0535-Excess Emissions Reporting and Malfunctions and NCAC
02Q .0508(f)(2)—Permit Content.......................................................................................15
3.3.2 15A NCAC 02Q.0508(n)-Permit Content........................................................................15
3.3.3 15A NCAC 02Q.0207-Annual Emissions Reporting........................................................15
3.3.4 15A NCAC 02D.0540-Particulate from Fugitive Dust Sources........................................15
List of Tables
Table 2-1 Emission Units at the Triangle Brick Wadesboro Facility.............................................................2
Table 2-2 Insignificant Activities at the Triangle Brick Wadesboro Facility...................................................4
Table 2-3 Actual Potential to Emit(PTE)for Triangle Brick Company.........................................................6
Table 3-1 Federal Regulation Applicability...................................................................................................7
Table 3-2 North Carolina Regulation Applicability......................................................................................12
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TRIANGLE BRICK COMPANY,WADESBORO CONTENTS
Title V Air Permit Renewal Application
List of Figures
Figure 2-1 Triangle Brick Fens line Wadesboro............................................................................................4
Figure2-2 Triangle Brick Wadesboro...........................................................................................................5
APPENDIX A NC DAQ APPLICATION FORMS
APPENDIX B POTENTIAL TO EMIT EMISSION CALCULATIONS
List of Acronyms
Btu British thermal units
CAA Clean Air Act
CFR Code of Federal Regulations
CHa methane
CO carbon monoxide
CO2 carbon dioxide
CO2e carbon dioxide equivalent
DAQ Division of Air Quality
DEQ Department of Environmental Quality
DLA Dry Lime Adsorber
EPA United States Environmental Protection Agency
ft3 Cubic feet
hr hour
HAP Hazardous Air Pollutant
HCI hydrogen chloride
HF hydrogen fluoride
lb(s) pound(s)
m3 cubic meter
MACT Maximum Achievable Control Technology
MM Million
NCAC North Carolina Administrative Code
NESHAP National Emission Standards for Hazardous Air Pollutants
N20 Nitrous Oxides
NOx Nitrogen oxides
NSPS New Source Performance Standards
PM particulate matter
PM10 particulate matter with an aerodynamic diameter less than 10 microns
PM2.5 particulate matter with an aerodynamic diameter less than 2.5 microns
PSD Prevention of Significant Deterioration
PTE potential to emit
S02 sulfur dioxide
TAP Toxic Air Pollutant
TBC Triangle Brick Company
TPER Toxic Pollutant Emission Rate
tph tons per hour
tpy tons per year
VOC volatile organic compound
yr year
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TRIANGLE BRICK COMPANY,WADESBORO INTRODUCTION
Title V Air Permit Renewal Application
1. INTRODUCTION
The Triangle Brick Company (TBC) -Wadesboro manufactures a variety of bricks from clay and shale
mined onsite. The facility holds a Title V Operating Permit Number 088179T11 that expires on 30 June
2023. As provided in Title V Permit Condition 3X and 15A North Carolina Administrative Code (NCAC)
02Q .0513, the permittee must submit a complete Title V renewal application at least six months prior to
the date of permit expiration. This application is intended to satisfy all the requirements of Title V of the
1990 Clean Air Act(CAA)as encoded in 40 Code of Federal Regulations (CFR) Part 70 and in 15A
NCAC 02Q .0500, "Title V Procedures."
Section 503(d) of the CAA and Title V Permit Condition 3X provides that, once a timely and complete
application for an operating permit has been filed, the applicant is shielded from enforcement action for
operating without a permit until the permit has been issued or other action has been taken on the
application. Therefore, by submitting this application, the TBC cannot be subject to enforcement action for
operating without a permit during the period in which this permit application is under review if the current
permit expires before a new permit is issued.
The TBC is not requesting any changes to the air permit as part of this renewal application.
This application is organized as follows:
- Section 2 includes a process overview of the TBC facility and facility-wide actual and potential
emissions.
- Section 3 includes a facility-wide regulatory applicability for federal and state air quality rules and
regulations.
- Appendix A includes relevant North Carolina Division of Air Quality (DAQ) application forms.
- Appendix B provides detailed potential to emit calculations. Detailed actual emissions were
submitted with the annual air emission inventory on 14 June 2022 through AERO.
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TRIANGLE BRICK COMPANY,WADESBORO FACILITY DESCRIPTION
Title V Air Permit Renewal Application
2. FACILITY DESCRIPTION
Triangle Brick Company-Wadesboro manufactures a variety of bricks from clay and shale mined onsite.
The material they mine is a consistent mixture of clay and shale.As the material is mined, it is trucked up
the hill to the facility where it is fed through a sizing grate. The smaller material passes via conveyors to
the storage shelter and the oversized material goes through a jaw crusher to reduce the size and then
continues to the storage shelter. There are two plants on site and the material from the storage shelter
feeds both. 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 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 kilns. Hydrogen Fluoride from the kilns is controlled by a dry lime adsorber(DLA)
installed on each kiln. The firing takes more than two days. After firing, the bricks are packaged into skid
loads (by a robot)and stored prior to purchase and shipment.
Table 2-1 provides a listing of the emission units present at the Wadesboro facility. Table 2-2 provides a
listing of the insignificant sources at the Wadesboro facility.
Table 2-1 Emission Units at the Triangle Brick Wadesboro Facility
Emission
Control
Source Emission Source Description Device ID Control Device Description
1D
One natural gas/No.2 fuel oil/No.6 fuel oil-
fired Brick Tunnel Kiln (29.0 tons per hour
K-1 (tph)material output rate, 42.8 million ' CD-K1 i Dry Limestone Adsorber(DLA)
British thermal units per hour(MMBtu/hr)
heat input rate)
One natural gas/No. 2 fuel oil/No. 6 fuel oil-
K-2 fired Brick Tunnel Kiln (29.0 tph material CD-K2 DLA
output rate, 42.8 MMBtu/hr heat in ut rate
One natural gas-fired Rotary Dryer(8.1
SD-1 tons of clay per hour, 0.3 MMBtu/hr heat ( NA NA
input rate
PC-1 and _
PC-2 Two shale feeders NA NA
PC-3 and Two scalp screens NA NA
PC-4
PC-5 aGnd Two jaw crushers NA NA
PC-7 One conveyor under PC-3 and PC-5 NA NA
PC-8 One conveyor under PC-4 and PC-6 NA NA
PC-9 One cross-over conveyor NA NA
PC-10 One shuttle conveyor NA NA
CG-1 One clay feeder NA NA
CG-2 One conveyor belt to scalping screen NA NA
CG-3 One scalping_screen NA NA
CG-4 One return conveyor belt for oversized from NA NA
screens
CG-5 One conveyor belt to hammer mill NA NA
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TRIANGLE BRICK COMPANY,WADESBORO FACILITY DESCRIPTION
Title V Air Permit Renewal Application
Table 2-1 Emission Units at the Triangle Brick Wadesboro Facility
Emission Control
Source Emission Source Description Control Device Description
ID Device ID
CG-6 One hammer mill NA NA
CG-7 One conveyor belt under hammer mill NA NA
CG-8 One conveyor belt to finish screens NA NA
CG-10 Four finish screens NA NA
CG-14 One fines conveyor belt under screens NA NA
CG-15 One conveyor belt to storage bins NA NA
CG-16 One conveyor belt over storage bins NA NA
CG-17 Five storage bins NA NA
CG-22 Five feeders under storage bins NA NA
CG-27 One conveyor in front of storage bins NA NA
CG-28 One conveyor to pug mill NA NA
CG-29 One clay feeder NA NA
CG-30 One conveyor belt to scalping screen NA NA
CG-31 One scalping screen NA NA
CG-32 One return conveyor belt for oversized from NA NA
screens
CG-33 One conveyor belt to hammer mill NA NA
CG-34 One hammer mill NA NA
CG-35 One conveyor belt under hammer mill NA NA
CG-36 One conveyor belt to finish screens NA NA
CG-37 Four finish screens NA NA
CG-41 One fines conveyor belt under screens NA NA
CG-42 One conveyor belt to storage bins NA NA
CG-43 One conveyor belt over storage bins NA NA
CG-44 Five storage bins NA NA
CG-49 Five feeders under storage bins NA NA
CG-54 One conveyor in front of storage bins NA NA
CG-55 One conveyor to pug mill NA NA
LS-1 Loam/sawdust feeder NA NA
LS-2 One conveyor from loam/sawdust feeder to NA NA
finish screens
LS-3 One loam screen NA NA
LS-4 One loam crusher NA NA
LS-5 One oversized return conveyor from LS-3 NA NA
LS-6 One oversized return chute NA NA
LS-7 One fines conveyor belt under LS-3 to NA NA
bunker belt conveyor
LS-8 One belt conveyor to bunker NA NA
LS-9 One storage bunker NA NA
LS-10 One sawdust screen NA NA
LS-11 One conveyor to storage bins NA NA
LS-12 One oversized covey or from sawdust NA NA
screen
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TRIANGLE BRICK COMPANY,WADESBORO FACILITY DESCRIPTION
Title V Air Permit Renewal Application
Table 2-2 Insignificant Activities at the Triangle Brick Wadesboro Facility
Emission
Source ID Emission Source Description
Number
IS-Tank 3,000 gallon above ground gasoline storage tank
IT-1 One 24,000 gallon above ground No.6 fuel oil storage tank
IT-2 and IT-3 Two 24,000 gallon above ground No.2 fuel oil storage tanks
IT-4 One 24,000 gallon above ground highway diesel fuel oil storage tank
IT-5 One 24,000 gallon above ground Additive"A"storage tank
2.1 Facility Location
The Wadesboro facility is located at 2960 US Highway 52N in Wadesboro (Anson County), North
Carolina. Figure 2-1 provides a map of the property fence line and Figure 2-2 provides a close-up view of
the facility.
Figure 2-1 Triangle Brick -Wadesboro
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TRIANGLE BRICK COMPANY,WADESBORO FACILITY DESCRIPTION
Title V Air Permit Renewal Application
Figure 2 2 Triangle Brick Wadesboro
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2.2 Facility Emissions
Table 2-3 provides a summary of the potential emissions for the Wadesboro facility. Emissions are
reported for various pollutants to the atmosphere, including the following-
■ filterable particulate matter(PM);
■ particulate matter with an aerodynamic diameter less than 10 microns (PM1o);
■ particulate matter with an aerodynamic diameter less than 2.5 microns (PM2.5);
■ nitrogen oxides (NOx),-
■ carbon monoxide (CO);
■ sulfur dioxide (S02)',
■ volatile organic compounds (VOC);
■ carbon dioxide(CO2);
■ methane (CH4);
■ nitrous oxides (N20);
■ carbon dioxide equivalent(CO2e)-, and
■ total hazardous air pollutants (HAPs).
Table 2-3 also provides a summary of the actual emissions from the Wadesboro facility as reported on
the 2021 emission inventory submitted via AEROS.
1 From Google Earth Pro,7.3.4.8642,Referenced 18 August 2022.
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TRIANGLE BRICK COMPANY,WADESBORO FACILITY DESCRIPTION
Title V Air Permit Renewal Application
Table 2-3 Actual Potential to Emit (PTE) for Triangle Brick Company
Y
Wadesboro Facility
Actual Potential Potential
2021 Emissions Emissions
Pollutant Emissions Before After
(tpy) Controls' Controls'
(tPY) (tPY)
PMc 28.68 69.57 69.57
PM10 90.32 210.53 210.53
PM2.5 90.32 209.52 209.52
NOx 13.86 75.18 75.18
CO 63.49 153.28 153.28
S02 33.01 250 250
VOC 7.03 14.70 14.70
CO2 21,908 60,620 60,620
CHa 0.41 2.45 2.45
N20 .041 0.49 0.49
CO2e 21,931 60,827 60,827
H F 0.53 24.11 2.44
Total HAPs 2.24 33.88 8.31
Max HAP 0.66 24.11 3.07
(HC)
a The only emission controls at the facility control hydrogen chloride(HCI)
and hydrogen fluoride(HF)emissions.
b Potential emissions are based on burning the maximum amount of
residual oil allowed by the permit and the assuming the remainder of the
year the facility burns natural gas in the kilns. Potential GHG emissions are
based on burning diesel fuel in all three kilns for the entire year.
PM emissions from the kilns are based on filterable particulate only.
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TRIANGLE BRICK COMPANY,WADESBORO REGULATORY ANALYSIS
Title V Air Permit Renewal Application
3. REGULATORY ANALYSIS
This section addresses the applicability of federal and state air quality regulations to the operations at The
TBC facility in Wadesboro, NC. The United States Environmental Protection Agency (EPA) has delegated
the authority to implement the Federal Title V Operating permit program to the North Carolina Division of
Environmental Quality (DEQ).As such, the NC DEQ rules regarding the issuance of the Title V permit
apply to the facility. The CFR and the NC DAQ Rules and Regulations were reviewed to determine
applicability to the TBC facility. Section 3.1 addresses federal regulatory applicability and Section 3.2
addresses the applicability of state rules to the facility.
3.r Federal Regulatory Applicability
Federal regulations have been promulgated that direct both the process of applying for a permit and the
performance standards of various types of emission units.A review of the Federal performance standards
and other federal rules that may apply to the operations is provided in the following sections CFR. Some
regulations that are not applicable are also included to clearly document their non-applicability.
A summary of the Federal Rule Applicability is provided in Table 3-1.
Table 3-1 Federal Regulation Applicability
Federal Regulations Citation Applicable?
Prevention of Significant Deterioration 40 CFR 52 Minor, Not
Applicable
New Source Performance Standards 40 CFR 60, Kb Not Applicable
New Source Performance Standards 40 CFR 60, 000 Applicable
New Source Performance Standards 40 CFR 60, UUU Applicable
National Emission Standards for Hazardous Air Pollutants 40 CFR 61 Not Applicable
National Emission Standards for Hazardous Air Pollutants for 40 CFR 63,
Affected Source Categories I CCCCCC Potentially'
National Emission Standards for Hazardous Air Pollutants for 40 CFR 63, Not Applicable
Affected Source Categories RRRRRR
Compliance Assurance Monitoring 40 CFR 64 Not Applicable
Chemical Accident Prevention Provisions 40 CFR 68 Not Applicable
State Operating Permit Programs 40 CFR 70 Applicable
Mandatory Greenhouse Gas Reporting 40 CFR 98 Not Applicable
a A gasoline tank is listed on the Insignificant List in the permit(see Table 2-2); however, the tank has not
yet been installed.
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TRIANGLE BRICK COMPANY,WADESBORO REGULATORY ANALYSIS
Title V Air Permit Renewal Application
3.1.1 40 CFR 52— Prevention of Significant Deterioration of Air Quality
The federal Prevention of Significant Deterioration (PSD) program, codified in 40 CFR Part 52.21,
requires any new major stationary source of air pollutants to obtain a major source air construction permit
before commencing construction. North Carolina has incorporated the federal PSD program in 15A North
Carolina Administrative Code(NCAC)2Q .0300. The PSD program applies to a facility if potential
emissions exceed applicable major source thresholds.
A facility is a major source under the PSD permitting program in accordance with 40 CFR 52.21(b)(1)(i) if
it is:
One of the listed stationary source categories in 40 CFR 52.21(b)(1)(1)(a)and has the potential to
emit greater than 100 tpy of one or more regulated NSR pollutants or 100,000 tpy of carbon
dioxide equivalent(CO2e)-, or
Any other stationary source which has the potential to emit 250 tpy or more of a regulated NSR
pollutant or 100,000 tpy of CO2e.
Potential to emit is defined in 40 CFR 52.21(b)(4) as:
"...the maximum capacity of a stationary source to emit a pollutant under its physical and
operational design. Any physical or operational limitation on the capacity of the source to
emit a pollutant, including air pollution control equipment and restrictions on hours of
operation or on the type or amount of material combusted, stored, or processed, shall be
treated as part of its design if the limitation or the effect it would have on emissions is
federally enforceable. Secondary emissions do not count in determining the potential to
emit of a stationary source."
The Triangle Brick facility has a SIC Code of 3271 -Concrete Block and Brick Manufacturing. It is not
considered one of the listed categories with a 100 tons per year(tpy) PSD major source threshold for
regulated New Source Review(NSR)pollutants. The Triangle Brick Wadesboro facility has not
undergone a PSD review. The facility avoided PSD review by limiting the amount Of S02 emitted to less
than 250 tons per year, and the facility is considered Minor for PSD purposes.
In comply with the PSD avoidance limit, the Triangle Brick keeps records of fuel burned and bricks
manufactured in the kilns. Using this information, the facility calculates and reports the amount of S02
emitted. Additionally, the facility limits the sulfur content of any fuel oil burned in the kilns.
3.1.2 40 CFR 60— New Source Performance Standards
New Source Performance Standards(NSPS), codified in Title 40 CFR Part 60, establish pollutant
emission limits and monitoring, reporting, and recordkeeping requirements for various emission sources
based on source type and size. The NSPS apply to new, modified, or reconstructed sources as defined
by each NSPS. North Carolina has incorporated the federal NSPS in 15A NCAC 02D.0524.
3.1.2.1 New Source Performance Standards Subpart Kb — Volatile Organic Liquid
Storage Vessels
This rule applies to liquid storage tanks constructed after July 23, 1984. The rule does not apply to tanks
that store liquids with a vapor pressure less than 3.5 kilopascals (kPa). The storage tanks at the Triangle
Brick facility store liquids with vapor pressures less than 3.5 kPa, so this rule does not apply to any tank
at the facility.
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TRIANGLE BRICK COMPANY,WADESBORO REGULATORY ANALYSIS
Title V Air Permit Renewal Application
3.1.2.2 New Source Performance Standards - Subpart UUU— Calciner and Dryers in
Mineral Industries
This rule applies to calciners and dryers located at mineral processing plants and that were constructed
after 1986. The rotary coatings dryer(SD-1) is subject to this rule.
The rule limits visible emissions and PM emissions from the rotary coatings dryer. In order to demonstrate
compliance, Triangle Brick performs regular visible emission checks of the rotary coatings dryer. If visible
emissions greater than normal are observed, Triangle Brick will conduct a more stringent visible emissions
determination (e.g., using a Method 9 test, as applicable). Triangle Brick also performs regular
maintenance on the rotary coatings dryer and keep records of all observations and maintenance. Records
are submitted to the DAQ twice per year.
For the rotary coatings dryer visible emissions cannot exceed 10%. Triangle Brick observes the source
daily for visible emissions. Triangle Brick inspects and maintains the rotary coatings dryer in accordance
with the manufacturer's recommendation and performs a semi-annual internal inspection for deterioration,
damage, and leaks. Records are reported to the DAQ twice per year.
3.1.2.3 New Source Performance Standards - Subpart 000— Nonmetallic Mineral
Processing Plants
This rule applies to mineral processing facilities that were built or modified after 1983 and crush mineral
material on-site. The mineral-handling sources at this facility are subject to this rule. The rule limits visible
emissions and PM emissions from emissions sources. The specific limit changes based on the type of
process, if the process is in an enclosed building, and/or if the emission sources was constructed after
2008. To demonstrate compliance with this rule, Triangle Brick performs monthly visible checks of the
mineral processing sources. If the visible emissions are observed to be greater than normal, Triangle
Brick will conduct a more stringent visible emissions determination (e.g., a Method 9 or a Method 22 test,
as applicable). Triangle Brick also performs regular maintenance on all sources and keep records of all
observations and maintenance. Records are reported to the DAQ twice per year.
Sources PC-3 through PC-10
For the primary crushing plant scalp screens,jaw crushers, and conveyors (ID Nos. PC-3 through PC-10),
the TBC must comply with the notification and recordkeeping requirements: dates of construction,
anticipated startup, and actual startup: performance test data; and excess emissions reports. The visible
emissions cannot exceed 10%, except for the crushers which cannot exceed 15%. Triangle Brick
observes the individual sources monthly for normal vs abnormal visible emissions. Triangle Brick submits
a summary report to the DAQ semiannually.
Sources CG-2 through CG-8 and CG-10 through CG-28
There are two clay grinding operations including: plant scalp screens, finish screens, hammer mill,
storage bins, feeders, and conveyors(ID Nos. CG-2 through CG-8 and CG-10 through CG-28); and scalp
screens, finish screens, hammer mill, storage bins, feeders and conveyors(ID Nos. CG-30 through CG-
55). The non-stack visible emissions cannot exceed 10%, except for crushers cannot not exceed 15%.
Triangle Brick observes building openings monthly for visible emissions or source stacks for normal or
abnormal visible emissions. Records are reported to the DAQ twice per year.
Sources LS-2 through LS-12
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 visible emissions cannot exceed 10%except for
crushers that cannot exceed 15%. Triangle Brick observes building openings monthly for visible
emissions. Records are reported to the DAQ twice per year.
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TRIANGLE BRICK COMPANY,WADESBORO REGULATORY ANALYSIS
Title V Air Permit Renewal Application
3.1.3 40 CFR 61 and 63— National Emission Standards for Hazardous Air
Pollutants
National Emission Standards for Hazardous Air Pollutants(NESHAP) are generally applicable to sources
of HAP. The NESHAP regulations in 40 CFR 61 are pollutant specific while the NESHAP regulations in
40 CFR 63 apply to sources in specifically regulated industrial source classifications. These emission
standards can regulate HAP emissions from major or area sources. A facility is classified as a major
source of HAP if the facility has the potential to exceed major source thresholds of 10 tpy of a single HAP
and 25 tpy of aggregate HAP.
The TBC facility in Wadesboro, NC, has the potential to emit HAPs in excess of the major source
threshold; however, per Permit Condition 2.1.A.4.a, the facility has requested a facility-wide HAP
emissions limit of 10 tpy of a single HAP and 25 tpy of total HAPs. Therefore, the facility is considered an
area source of HAPs.An analysis of potentially applicable NESHAP subparts is presented below.
3.1.3.1 40 CFR 63 Subpart CCCCCC— Gasoline Dispensing
This rule applies to all sources that dispense gasoline and are located at HAP-Area Sources. The rule
differentiates between sources based on their monthly dispensing rate. The gasoline tank IS-Tank6 is
subject to this rule and is subject to the sub-10,000 gallons per month category. However, IS-Tank has
not yet been installed at the facility. According to§63.111110), no other parts of this rule apply to the IS-
Tank.
Since this rule only applies to IS-Tank listed on the Insignificant Activities list, the Title V permit does not
include a specific condition for this rule.
3.1.3.2 40 CFR 63 Subpart RRRRR— Clay Ceramics Manufacturing Area Sources
This rule applies to all sources that meet the definition of"clay ceramics manufacturing facility" in
§63.11444. Brick manufacturing is not included in this definition, so this rule does not apply to this facility.
3.1.4 40 CFR 64— Compliance Assurance Monitoring (CAM)
The Compliance Assurance Monitoring (CAM) Rule (40 CFR Part 64)applies to pollutant-specific
emissions units (PSEU)that:
(1) are subject to an emission limit or standard,
(2) use a control device to achieve compliance with an emission limit or standard for the
applicable regulated air pollutant(or a surrogate thereof); and
(3) have emissions potential pre-control device emissions in the amount required to classify the
unit as a major source under Part 70 of the CAA. Part 64 does not apply to emission sources
subject to limitations or standards proposed after 15 November 1990, pursuant to section 111 or
112 of the CAA(e.g., post-1990 NSPS or NESHAP).
Facilities are required to address CAM as part of the Title V permitting process.
The only control devices used at the Triangle Brick facility are for hydrogen chloride and hydrogen
fluoride, which are both HAPs and TAPs. The permit contains two emission limits for these pollutants:
02Q .0317 and 02D .1100. Emission limits under 15A NCAC 02Q .0317 do not trigger CAM because
they are exempt per 15A NCAC 02D .0614(b)(1)(E). TAPS do not have a major source threshold.
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TRIANGLE BRICK COMPANY,WAOESBORO REGULATORY ANALYSIS
Title V Air Permit Renewal Application
3.1.5 40 CFR 68- Chemical Accident Prevention Provisions
An facility that stores or uses an of h y y y the regulated substances listed In 40 CFR§68.130 In a quantity
greater than the applicable threshold quantity must develop a site-specific Risk Management Plan (RMP).
The level of analysis required in the RMP depends on the amount and type of substance used/stored and
whether there are any offsite impacts associated with a worst-case release of a regulated substance.
The TBC does not use/store any of the regulated substances in amounts greater than the applicable
threshold quantity; therefore, the Chemical Accident Prevention Provisions do not apply to the facility.
3.1.6 40 CFR 70- Title V Operating Permit Program
A Title V(Part 70) operating permit is required for facilities that meet the definition of a major source
according to 40 CFR Part 70.2. A facility with criteria pollutant emissions greater than 100 tpy, 10 tpy of a
single HAP, or 25 tpy of a combination of HAPs is considered a major source under the Title V permitting
program. In addition, a facility may also be required to obtain a Part 70 (Title V) permit under a NSPS or
NESHAP regulation.
The TBC is required to obtain a Title V permit and currently operates under Permit 08179/T11.
The permit requires that a Title V renewal application is required to be submitted at least six months
before the date of permit expiration. This application satisfies the requirements for submittal of a complete
renewal application.
3.1.7 40 CFR 98- Mandatory Greenhouse Gas Reporting
In addition to specific types of listed facilities, any other facility that has an aggregate maximum rated heat
input capacity of the stationary fuel combustion units at the facility of 30 MMBtu/hr or greater and emits
25,000 metric tons CO2e or more per year in combined emissions from all stationary fuel combustion
sources, must submit an annual GHG report for emissions from the stationary fuel combustion sources
only.
Facility wide potential annual emissions Of CO2e assuming continuous operation of each CO2e emission
source at maximum capacity are greater than 25,000 metric tons; therefore, The TBC is required to
submit an annual report under this rule when actual emissions exceed 25,000 metric tons CO2e or more
per year. As shown in Table 2-3 actual emissions do not exceed 25,000 metric tons.
3.2 State Regulatory Applicability
Applicability analysis of potentially applicable standards under 15A NCAC Section 02, "Environmental
Management," are discussed in the sections below. Table 3-2 provides a summary of rules with possible
applicability to the Triangle Brick Wadesboro facility.
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TRIANGLE BRICK COMPANY,WADESBORO REGULATORY ANALYSIS
Title V Air Permit Renewal Application
Table 3-2 North Carolina Regulation Applicability
State Regulation Citation Applicable?
Particulates from Miscellaneous Industrial Processes 15A NCAC 02D .0515 Applicable
Sulfur Dioxide Control Requirement 15A NCAC 02D .0516 Applicable
Visible Emissions Control Requirement 15A NCAC 02D .0521 Applicable
New Source Performance Standard Subpart UUU -
Standards of Performance for Calciners and 15A NCAC 02D .0524 Applicable
Dryers in Mineral Industries
New Source Performance Standard Subpart 000 - 15A NCAC 02D .0524 Applicable
Volatile Organic Compounds 15A NCAC 02D .0900 Not Applicable
Nitrogen Oxides 15A NCAC 02D .1600 Not Applicable
Toxic Air Pollutant Emission Limitations and 15A NCAC 02D .1000 Applicable
Reporting Requirement
Maximum Achievable Control Technology 15A NCAC 02D .1111 Not Applicable
Control and Prohibition of Odorous Emissions 15A NCAC 02D .1806 Applicable
Avoidance for MACT 15A NCAC 02Q .0317 Applicable
Avoidance Condition for 15A NCAC 2D .0530 15A NCAC 02Q .0317 Applicable
Prevention of Significant Deterioration
Title V Procedures 15A NCAC 02Q .0500 Applicable
Reporting Requirements for Excess Emission and 15A NCAC 02D .0535 Applicable
Permit Deviations
General
Permit Content(Compliance Certification) Conditions15A NCAC Applicable
02Q .0508(n)
General Conditions
Annual Emissions Reporting Applicable
15A NCAC 02Q .0207
General Conditions
Particulate from Fugitive Dust Sources Applicable
15A NCAC 02D .0540
3.2.1 15A NCAC 2D .0515- Particulates from Miscellaneous Industrial Processes
15A NCAC 02D .0515 applies to specific manufacturing process industries and general manufacturing
processes for which PM emission limits are not specified elsewhere. The facility operates emission
sources which are included in this category. Therefore, those sources are subject to the allowable
emission rate as calculated in the following equation:
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TRIANGLE BRICK COMPANY,WADESBORO REGULATORY ANALYSIS
Title V Air Permit Renewal Application
E = 4.10 x P0.67 (P< 30 tons/hr)
E = 55.0W)"'—40 (P> 30 tons/hr)
Where:
E = allowable emission rate in pounds per hour
P = process weight in tons per hour
Particulate emissions from each kiln (K-1 and K-2), cannot exceed the hourly emission limit calculated
using the above equations. Triangle Brick is required to conduct a semiannual visual inspection of kiln
emissions ductwork and a semi-annual visual inspection of the kiln's fuel combustion system and send
summary reports to the DAQ twice per year.
3.2.2 15A NCAC 2D .0516 - Sulfur Dioxide Control Requirement
This rule applies to sources that emit sulfur dioxide(S02)from any source of combustion and requires
that each source cannot exceed 2.3 pounds of S02 per million BTU input. Triangle Brick will continue to
comply with the 2.3 pounds Of S02 per million BTU input limit by firing solely natural gas.
Sulfur dioxide emissions from each kiln (K-1 and K-2)and from rotary coatings dryer SD-1 are not to
exceed 2.3 pounds per million British thermal units(lb/MMBtu) heat input. For kilns K-1 and K-2, Triangle
Brick monitors the sulfur content and the Btu content of the No. 6 fuel oil through fuel supplier
certifications. There are no monitoring requirements when using natural gas or No. 2 fuel oil. Triangle
Brick will continue to comply with the 2.3 pounds of S02 per million BTU input limit by firing solely natural
gas or by firing ultra-low sulfur diesel fuel. If Triangle Brick uses No. 6 fuel oil it will monitor the sulfur
content and the Btu content of the No. 6 fuel oil through fuel supplier certifications and keep a quarterly
log of fuel certifications when using No. 6 fuel oil.
3.2.3 15A NCAC 2D .0521 - Control of Visible Emissions
This rule applies to"industrial processes where an emission can reasonably be expected to occur". For
sources installed after July 1, 1971, visible emissions are limited to no more than 20 percent opacity when
averaged over a six-minute period.Visible emissions from kilns K-1 and K-2 cannot be more than 20
percent opacity. Triangle Brick observes the kiln emission points once each month for normal vs
abnormal conditions and submit summary reports to the DAQ twice a year.
3.2.4 15A NCAC 2D .0524 - New Source Performance Standards Subpart UUU-
Standards of Performance for Calciners and Dryers in Mineral Industries
See Section 3.1.2.1 for discussion of this regulation.
3.2.5 15A NCAC 02D .0900- Volatile Organic Compounds
15A NCAC 02D .0900 sets standards for VOCs for specific source categories statewide and for others
that are located in specific areas. The TBC facility does not meet the category and/or applicable
thresholds of the sections that apply to facilities statewide as listed in 15A NCAC 02D .0902(e), nor is it
located in any of the areas listed in the rule. Therefore, the requirements of 15A NCAC 02D .0900 are not
applicable.
3.2.6 15A NCAC 02D .1100- Toxic Air Pollution Emission Limitations and
Reporting Requirement and 15A NCAC 02Q .0700- Toxic Air Pollutant
Procedures
The Toxic Air Pollutant(TAP) Procedures require a permit for any facility with emissions of a Toxic Air
Pollutant listed in 15A NCAC 02D .1104 in excess of the applicable Toxic Pollutant Emission Rates
(TPERs) presented in 15A NCAC 02Q .0711.
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TRIANGLE BRICK COMPANY,WADESBORO REGULATORY ANALYSIS
Title V Air Permit Renewal Application
According to the air toxic compliance demonstration, Toxic Air Pollutant(TAP) emissions will not exceed
the established emission limits if they are controlled by limiting the amount of clay and additives
processed in each of the kilns (K-1 and K-2)to 58,000 pounds per hour(lb/hour) (29 tons per hour[tph]).
Triangle Brick submits a quarterly summary report to DAQ on this information. There are no changes
proposed as part of this Title V renewal application; therefore, TAP emissions will remain below the
TPERs, and an air dispersion modeling analysis is not required.
3.2.7 15A NCAC 02D .1111- Maximum Achievable Control Technology
15A NCAC 02D .1111 references National Emission Standards for Hazardous Air Pollutants (NESHAPs)
for source categories promulgated under 40 CFR Part 63 (also known as the"Maximum Achievable
Control Technology," or MACT, standards). The facility has requested a facility-wide HAP emissions limit
of 10 tpy of a single HAP and 25 tpy of total HAPs, or MACT Avoidance Condition, under 15A NCAC 02Q
.0317. Therefore, the facility is considered an area source of HAPs.
3.2.8 15A NCAC 02D .1400- Nitrogen Oxides
15A NCAC 02D .1400 sets standards for nitrogen oxides (NOX)for specific source categories statewide
and for others that are located in specific areas of the state. The TBC does not have any of the sources
applicable to this standard for facilities statewide, nor is it located in one of the listed areas of the state,-
therefore, the requirements of 15A NCAC 02D .1400 are not applicable.
3.2.9 15A NCAC 02D .1806- Control and Prohibition of Odorous Emissions
Triangle Brick prevents odorous emissions from the facility from causing or contributing to objectionable
odors beyond the facility's boundary.
3.2.10 15A NCAC 02Q .0317-Avoidance of the Applicability of Major Source
MACT Standards
To remain classified minor source for HAPS and avoid MACT requirements, facility emissions of HAPs
must be less than 10 tpy of each individual HAP and less than 25 tpy total HAPs. Monitoring,
Recordkeeping and Reporting requirement are established in permit to demonstrate facility remains minor
source for HAPS. These requirements are summarized as followed:
Monitoring and Recordkeeping Requirements.
■ Triangle Brick operate the DLAs(CD-K 1 and K2)when Kilns (K- I and K-2)are operating, except
during periods of startup, shutdown, or malfunction or during operation in bypass mode for routine
maintenance of the DLAs.
• The DLAs maintain an adequate amount of limestone.
■ The same grade of limestone used during the performance testing is used during operations.
• Triangle Brick maintains the limestone feeder rate settings at or above the settings established during
the performance test. Triangle Brick monitors the feeder rate setting and records the reading each
day.
■ Triangle Brick monitors the bypass damper position and records the result when Kilns are operated
when the damper is open.
■ Triangle Brick records the production rate on a fired product basis for each Kiln and keeps these
records.
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TRIANGLE BRICK COMPANY,WADESBORO REGULATORY ANALYSIS
Tide V Air Permit Renewal Application
3.2.11 15A NCAC 02Q .0317-Avoidance Condition for 15A NCAC 2D .0530-
Prevention of Significant Deterioration
The sulfur dioxide emissions from each kiln must be less than 250 tons per 12-month period. K-1 and K-2
production throughput is limited to 58,000 lb/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. Both kilns are required monthly to calculate and
record S02emissions. K-1 has quarterly summary reporting of S02 emissions and fuel combustion
quantities. K-2 has semi-annual summary reporting Of S02 emissions and fuel combustion quantities.
3.2.12 15 NCAC 02Q. 0500- Title V Procedures
The TBC is required to obtain a Title V permit and currently operates under Permit 08157T14. See
Section 3.1.6 for detailed discussion.
3.3 General Conditions
The following are general conditions that are listed in the Title V permit that require specific actions by
Triangle Brick.
3.3.1 15A NCAC 02D .0535- Excess Emissions Reporting and Malfunctions and
NCAC 02Q .0508(t)(2)- Permit Content
The facility is required to report excess emission events and malfunctions that last more than 4 hours per
the requirements of 15A NCAC 2D .0535(f).
3,3.2 15A NCAC 02Q .0508(n) - Permit Content
Triangle Brick submits an Annual Compliance Certification (ACC) report postmarked before March 1 of
each year, stating compliance with all permit conditions, or noting any deviations during the previous
calendar year.
3.3.3 15A NCAC 02Q .0207- Annual Emissions Reporting
Triangle Brick is required to submit an Annual Emission Inventory postmarked on or before June 30th of
each year. Triangle Brick submits this inventory through the DAQ's online inventory system AERO.
3.3.4 15A NCAC 02D .0540- Particulate from Fugitive Dust Sources
Triangle Brick does not cause or allow fugitive dust emissions to cause or contribute to substantive
complaints or excess visible emissions beyond the property boundary.
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APPENDIX A NC DAQ APPLICATION FORMS
B-16 __ I�

FORM A
GENERAL FACILITY INFORMATION
REVISED 04/18/19 NCDEQ/Division of Air Quality-Application for Air Permit to Construct/Operate A
>JE_APPLICATION WILL NOT BE PROCESS
Local Zoning Consistency Determination
(new or modification onl Appropriate Number of Copies of Application Application Fee(please check one option below)
Y)
21
121 Responsible Official/Authorized Contact Signature P.E.Seal(if required) Not Required ePayment ®Check Enclosed
GENERAL INFORMA`nON �,,
Legal Corporate/Owner Name,Triangle Brick Company-Wadesboro
Site Name: Wadesboro
Site Address(911 Address)Line 1:US Highway 52
Ste Address Line 2:
city:Wadesboro State North Carolina
Zip Code: 28170 County:Anson
i i,
Responsible OfficiaLlAuthorized Contact:I'loward P.Brown.Ir. Invoice Contact:Howard P.Brown Jr.
Name/Title: President&CEO Name/Title:President&CEO
Mailing Address Line 1:6523 Hwy 55 Mailing Address Line 1:6523 Hwy 55
Mailing Address Line 2: Mailing Address Line 2:
City: Durham State:NC Zip Code:27713 City: Durham State: NC Zip Code:27713
Primary Phone No.:(919)544-796 Fax No.: [phone] Primary Phone No.:(919)544-796 Fax No.: [phone]
Secondary Phone No.: Secondary Phone No.:
Email Address:HowardB(a trian lebrick.coin Email Address:Howard B;�i�triant;lebrick.com
FacilVinspection Contact Howard P.Brown Jr. Pennimchnica/Contact:Howard P.Brown Jr.
Name/Title:President&CEO Name/Title:President&CEO
Mailing Address Line 1:6523 Hwy 55 Mailing Address Line 1:6523 Hwy 55
Mailing Address Line 2: Mailing Address Line 2:
City: Durham State: NC: Zip Code: 27713 City: Durham State: NC Zip Code: 27713
Primary Phone No.:(919)544-796 Fax No.: [phone] Primary Phone No.:(919)544-796 Fax No.: [phone]
Secondary Phone No.: Secondary Phone No.:
Email Address:HowardB12trianglebrick.com Email Address:HowardB(a`trianglebrick.com
A'PLICATION IS BEING '. r
New Non-permitted Facility/Greenfield ❑Modification of Facility(permitted) Renewal Title V Renewal Non-Tdle V
Name Change Ownership Change Administrative Amendment Renewal with Modification
FACILITY CLASSIFICATION AFTER APPLICATION(Check Only One)
General -004
Small Prohibitory Small Synthetic Minor Title V
PACILrrY(Plant Site)INFO MA ON
Describe nature of(plant site)operation(s):
Facility ID No.0400043
Primary SIC/NAICS Code:3251 Current/Previous Air Permit No.08179T11
Expiration Date:6/30/2023
Facility Coordinates: Latitude:35'01'10.61"N Longitude:80`05'07.10'W
Does this application contain confidential data? O YES C NO -If yes,please contact the DAQ Regional Office prior to submitting this application."`
(See Instructions)
Person Name:Kevin Eldridge Firm Name:ERM NC.!nc.
Mailing Address Line 1:4140 Parklake Ave#110 Mailing Address Line 2:
City:Raleigh State:NC Zip Code:27612 County:Wake
Phone No.:[phone] Fax No.:[phone] Email Address:[e-mail]
VA
Name(typed):Howard P.Brown Jr. Title.President&CEO
X Signature(Blue Ink): 0 Date:
A /1/17
Attach Additional Sheets As Necessary Page 1 of 2

FORM A (continued, page 2 of 2)
GENERAL FACILITY INFORMATION
REVISED 04/18/19 NCDEQ/Division of Air Quality-Application for Air Permit to Construct/Operate A
SECTION
(Company Name)hereby formally requests renewal of Air Permit
There have been no rMWifications to the originally permitted facility or the operations therein that would require an air permit since the last permit was issued.
Is your facility subject to 40 CFR Part 68'Prevention of Accidental Releases"-Section 112(r)of the Clean Air Act? Q YES 0 NO
If yes,have you already submitted a Risk Manage Plan(RMP)to EPA? 0 YES © NO Date Submitted.
Did you attach a current emissions inventory? 0 YES NO
If no,did you submit the inventory via AERO or by mail? Via AERO Mailed Date Mailed
In accordance with the provisions of Title 15A 2Q.0513,the responsible official of Triangle Frick Com ari -Wa::ieshoio (Company Name)
hereby formally requests renewal of Air Permit No. pg 1 79 T1 j (Air Permit No)and further certifies that:
(1) The current air quality permit identifies and describes all emissions units at the above subject facility,except where such units are exempted under the North Carolina Title V regulations at
15A NCAC 2Q.0500:
(2) The current air quality permit cites all applicable requirements and provides the method or methods for determining compliance with the applicable requirements:
(3) The facility is currently in compliance,and shall continue to comply,with all applicable requirements. (Note: As provided under 15A NCAC 2Q.0512,compliance with the conditions of the
pennit shall be deemed compliance with the applicable requirements specifically identified in the permit):
(4) For applicable requirements that become effective during the term of the renewed permit that the facility shall comply on a timely basis:
(5) The facility shall fulfill applicable enhanced monitoring requirements and submit a compliance certification as required by 40 CFR Part 64,
The responsible official(signature on page 1)certifies under the penalty of law that all information and statements provided above,based on information and belief formed after reasonable inquiry,are true,
accurate,and complete.
APPLICA., OR NAM
New Facility Name:
Former Facility Name:
An official facility name change is requested as described above for the air permit mentioned on page 1 of this form. Complete the other sections if there have been modifications to the originally permitted
facility that would require an air quality permit since the last permit was issued and if there has been an ownership change associated with this name change.
By this application we hereby request transfer of Air Quality Permit No. from the former owner to the new owner as described below.
i
The transfer of permit responsibility,coverage and liability shall be effective (immediately or insert date.) The legal ownership of the
facility described on page 1 of this form has been or will be transferred on (date). There have been no modifications to the originally
permitted facility that would require an air quality permit since the last permit was issued.
Signature of New(Buyer)Responsible Official/Authorized Contact(as typed on page 1)
X Signature(Blue Ink):
Date:
New Facility Name:
Former Facility Name:
Signature of Former(Seller)Responsible Official/Authorized Contact.
Name(typed or print):
Title:
X Signature(Blue Ink):
Date:
Former Legal Corporate/Owner Name:
In lieu of the sellers signature on this form,a letter may be submitted with the seller's signature indicating the ownership change
Describe the requested administrative amendment here(attach additional documents as necessary):
Attach Additional Sheets As Necessary Page 2 of 2

FORM E5
TITLE V COMPLIANCE CERTIFICATION (Required)
REVISED 09/22/16 NCDEQ/Division of Air Quality-Application for Air Permit to Construct/Operate E5
In accordance with the provisions of Title 15A NCAC 2Q.0520 and.0515(b)(4)the responsible company official of.-
SITE NAME: Triangle Brick Company-Wadesboro
SITE ADDRESS: US Hwy 52
CITY,NC: Wadesboro.North Carolina
COUNTY: Anson
PERMIT NUMBER: 08179T11
CERTIFIES THAT(Check the appropriate statement(s):
❑✓ The facility is in compliance with all applicable requirements
In accordance with the provisions of Title 15A NCAC 2Q.0515(b)(4)the responsible company official certifies that the proposed minor
modification meets the criteria for using the procedures set out in 2Q.0515 and requests that these procedures be used to process the permit
application.
❑ The facility is not currently in compliance with all applicable requirements
/f this box is checked,you must also complete Form E4"Emission Source Compliance Schedule"
The undersigned certifies under the penalty of law,that all information and statements provided in the application, based on
information and belief formed after reasonable inquiry,are true,accurate,and complete.
Date:
Signature of responsible company official(REQUIRED,USE BLUE INK)
Howard P. Brown Jr.-President&CFO
Name,Title of responsible company official(Type or print)
Attach Additional Sheets As Necessary

FORM E6
COMPLIANCE ASSURANCE MONITORING (CAM) PLAN (4 pages)
REVISED 09/22/16 NCDEQ/Division of Air Quality-Application for Air Permit to Construct/Operate E6-1
For CAM-affected emission units,the applicant must submit additional information in the form of a CAM Plan as required under 40 CFR 64.
For information about the CAM rule and this form,please refer to 40 CFR 64 and 15A NCAC 2D.0614.
Additional information(including guidance documents may be found at the following URLs:
https://www3.epa.gov/ttn/emc/cam html
_https://deg.nc.gov/about/divisions/air-Quality/air-quality-enforcement/compliance-assurance-monitoring
1. Facility Name: Triangle Brick Company-Wadesboro
2. PermitNumber: 1�u ber: O8 .9T 11
3. Date Form Prepared: 9/20/2022
BASIS OF CAM SUBMITTAL
4. Mark the appropriate box below as to why this CAM Plan is being submitted as part of this application:
❑✓ Renewal Application: ALL Emission Units(Pollutant Specific Emission Units[PSEUs]considered separately with respect to EACH regulated air
pollutant)for which a CAM Plan has NOT yet been approved needs to be addressed in this CAM Plan submittal.
See Renewal Procedures per 15 A NCAC 2Q.0513
❑ Initial Application(Submitted after 4/20/1998): Only large PSEUs(PSEUs with potential post control device emissions of an applicable regulated air
pollutant that are equal to or greater than major source threshold levels)need to be addressed in this CAM Plan submittal.
See Initial Application Procedures per 15A NCAC 2Q.0505(1).
❑ Significant Modification to Large PSEUs: Only large PSEUs(PSEUs with potential post control device emissions of an applicable regulated air
pollutant that are equal to or greater than major source threshold levels)being modified after 4/20/1998 need to be addressed in this CAM Plan submittal.
For large PSEUs with an approved CAM Plan.only address the appropriate monitoring requirements affected by the significant modification.
See Significant Modification Procedures per 15 A NCAC 20.0516.
5. To determine CAM applicability,a PSEU must meet ALL of the following criteria(if not,then the remainder of this form need not be completed):
A. The PSEU is located at a major source;
B. The PSEU is subject to an emission limitation or standard for the applicable regulated air pollutant that is NOT exempt;
List of EXEMPT Emission Limitations or Standards below OR as provided in 15A NCAC 2Q.0614(b)(1):
• NSPS(40 CFR Part 60)or NESHAP(40 CFR Part 61 and 63)proposed after 11/15/1990,
• Stratospheric ozone protection requirements.
• Acid Rain program requirements.
• Emission limitations or standards for which a Title V permit specifies a continuous compliance determination method,as defined in the
CAM rule(40 CFR 64.1),Continuous Compliance Determination Method.
• An emission cap that meets the requirements specified in 40 CFR 70.4(b)(12).
If the PSEU is subject to both Exempt and Not Exempt emission standards for the same pollutant, then the facility is required to determine the
CAM applicability for Not Exempt emission standards.
C. The PSEU uses an add-on control device to achieve compliance with an emission limitation or standard,
D. The PSEU has potential pre-control device emissions of the applicable regulated air pollutant that are equal to or greater than major source
threshold levels;and
E. The PSEU is NOT an exempt backup utility power emission unit that is municpally owned and appropriately documentd as provided in
15A NCAC 2D.0614(b)(2).
Attach Additional Sheets As Necessary Page 1 of 4

BACKGROUND!DATA AND INFORMATION %//%%// / `% E6-2
6. Complete the following table for ALL PSEUs that need to be addressed in this CAM Plan submittal. This section is to be used to provide
background data and information for each PSEU in order to supplement the submittal requirements specified in 40 CFR 64.4.
If additional space is needed,elease attach and label additional sheets as appropriate.
i% �i/%//,i /,,/!!// 'Emission
PSEU PSEU Control Limitation OR Monitoring
Designation Description Pollutant Device Standard Requirement
a Indicate the emission limitation or standard for any applicable requirement that constitutes an emisson limitation,emission standard.,or standard of
performance. Examples of emission limitations or standards may include a permitted emission limitation applicable regulations.work practices,process or
control device parameters,or other forms of specific design,equipment,operational or maintenance requirements.
° Indicate the monitoring requirements for the control device that are required by an applicable regulation or permit condition.
Attach Additional Sheets As Necessary Page 2 of 4

CAM MONITORING APPROACH CRITERIA E6-3
7 Complete this section for EACH PSEU and for each affected pollutant that needs to be addressed in this CAM Plan submittal. This section may be
copied as needed for each PSEU. This section is to be used to provide monitoring data and information for EACH indicator selected for EACH PSEU in
order to meet the monitoring design criteria specified in 40 CFR 64.3 and 64.4. If more than two indicators are being selected for a PSEU or if additional
space is need,attach and label with the apprtopriate PSEU designation,pollutant,and indicator Nos.
/ //" i/ / "INDICATOR"INDICATORNO. Nns
7a. General Criteria
Describe the monitoring approach used to
measure the indicators.
Establish the appropriate indicator range or
the procedures for establishing the indicator
range which provides a reasonable
assurance of compliance
Provide Quality Improvement Plan(QIP)
Threshold levels.
7b. Performance criteria
Provide the Specification for Obtaining
Representative Data(Such as detector
location and insta;lation specifications).
Provide Quality Assurance and Quality
Control(QA/QC)Practices that are adequate
to ensure the continuing validity of the data.
considering manufacturerer's
recommendations
Provide the Monitoring Frequency
Provide the Data Collection Procedures that
will be used
Provide the Data Averaging Period for the
purpose of determining whether an
excursion or exceedance has occurred.
a If a Continuous Emission Monitoring System(CEMS),Continuous Opacity Monitoring System(COMS).or Predictive Emission Monitoring System(PEMS)is used,
then this section need not be completed ONLY for the CEMS,COMS,or PEMS;EXCEPT that the Special Criteria Information of 40 CFR 64.3(d)must be
provided. Special Criteria Information may be provided on a separate sheet.
Describe all indicators to be monitored which satisfy 40 CFR 64.3(a). Indicators of emission control performance for the control device and associated capture
system may include measured or predicted emissions(including visible emissions or opacity),process and control device operating parameters that affect control
device(and capture system)efficiency or emission rates,or recorded findings of inspection and maintenance activities.
Indicator ranges may be based on a single maximum or minimum value or at multiple levels that are relevant to distinctly different operating conditions,expressed
as a function of process variables,expressed as maintaining the applicable indicator in a particular operational status or designated condition,or established as
interdependent between more than one indicator. In addition,unless specifically stated otherwise by an applicable requirement the owner or operator shall
monitor the indicators to detect any bypass of the control deivice(or capture system)to the atmosphere.
d The QIP threshold is based on the number of excursions identified in a reporting {p g period. (Example: if the historical monitoring data for a facility indicates that the
indicator range was exceeded 10 times in a 6-month period,the threshold could be established at no more than 10 excursions outside the indicator range during a
6-month reporting period.) The threshold levels also could be established based on the duration of excursions as a percentage of operating time
At a minimum,the owner of a large PSEU must collect four or more data values equally spaced over each hour and average the values. All other PSEUs must
collect data at least once per 24-hour period or possibly more to provide reasonable assurance of complliance over the anticipated range of operating conditions.
Attach Additional Sheets As Necessary Page 3 of 4

RATIONALE AND JUSTIFICATION E6-4
8. Complete this section for EACH PSEU and for each affected pollutant that needs to be addressed in this CAM Plan submittal. This section may be
copied as needed. Use this section to provide monitoring data and information for EACH indicator selected for EACH PSEU in order to meet the
monitoring design criteria specified in 40 CFR 64.3 and 64.4. If more than two indicators are being selected for a PSEU or if additional speace is
needed,attach additional sheets and label with the appropriate PSEU designation,pollutant,and indicator Nos.
PSEU DESIGNATION POLLUTANT
9. INDICATORS AND THE MONITORING APPROACH: Provide the rationale and justification for the selection of the indicators and the monitoring approach used to
measure the indicators. Also provide any data suporting the rationale and justification. Explain the reasons for any differences between the verification of
operational status or the quality assurance and control practices proposed and the manufacturer's recommendations. (If addiional space is needed,attach and
label with the appropirate PSEU designation and pollutant).
10. INDICATOR RANGES: Provide the rationale and justification for the selection of the indicator ranges. The rationale and justification shall indicate how EACH
indicator range was selected by either a Compliance or Performance Test,a Test Plan and Schedule,or by Engineering Assessments. Depending on which
method is being used for each indicator range,include the specific information required below for that specific indicator range (If additional space is needed;
attach and label with the appropriate PSEU designation and pollutant):
• COMPLIANCE or PERFORMANCE TEST(Indicator ranges determined from control device operating parameter data obtained during a compliance or
performance test conducted under regulatory specified conditions or under conditions representative of maximum potential emissions under anticipated
operating conditions. Such data may be supplemented by engineering assessments and manufacturer's recommendations). The rationale and justification
shall include a summary of the compliance or performance test results that were used to determine the indicator range and documentation indicating that no
changes have taken place that could result in a significant change in the control system perfornmace or the selected indicator ranges since the compliance or
performance test was conducted and approved by DAQ.
• TEST PLAN AND SCHEDULE(Indicator ranges will be determined from a proposed implementation plan and schedule for installing,testing,and performing
any other appropriate activities prior to use of the monitoring). The rationale and justification shall include the proposed implementation plan and schedule
that will provide for use of the monitoring as expeditiously as practical after approval of this CAM Plan;but in no case shall the schedule for completing
installation and beginning operation of the minitoring exceed 180 days after approval.
• ENGINEERING ASSESSMENTS(Indicator ranges or the procedures for establishing indicator ranges are determined from engineering assessments and
other data.such as manufacturer's design criteria and historical monitoring data,because factors specific to the type of monitoring,control device,or PSEU
make compliance or performance testing unnecessary). The rationale and justification shall include documentaion demonstrating that compliance testing is
not required to establish the indicator range.
RATIONALE AND JUSTIFICATION:
Attach Additional Sheets As Necessary Page 4 of 4

APPENDIX B POTENTIAL TO EMIT EMISSION CALCULATIONS
B-17

Potential to Emit Summary
Triangle Brick Company
Wadesboro,North Carolina
NC TAP 2021 Actual Emissions' Total Potential Emissions Total PotentialEmissions
Pollutant &/m'HAP Uncontrolled (Controlled)'
1 tPy 1 tpy I
TSP Neither 57,358 28.68 139,143 69.57 139,143 69.57
PM, Neither 180,632 90.32 421,057 210.53 421,057 210.53
PM2.5 Neither 180,632 90.32 419,048 209.52 419,048 209.52
502 Neither 66,024 33.01 500,000 250.00 500,000 250.00
NOx Neither 27,730 13.86 150,365 75.18 150,365 75.18
CO Neither 126,986 63.49 306,555 153.28 306,555 153.28
VOC Neither 14,053 7.03 29,395 14.70 29,395 14.70
CO2 Neither 21,908 60,620 60,620
NH4 Neither 0.41 2.45 2.45
N20 Neither 0.041 0.49 0.49
CO2e Neither 21,931 60,827 60,827
1,1,1 Trichloroethane TAP/HAP 1.03 5.17E-04 3.02 1.51E-03 3.02 1.51E-03
1,4 Dichlorobenzene TAP/HAP 10.56 5.28E-03 24.39 0.012 24.39 1.22E-02
2-Butanone MEK TAP/HAP 48.42 0.024 111.78 0.056 111.78 0.056
2-Hexanone MBK Neither 18.71 9.35E-03 43.19 0.022 43.19 0.022
Acetaldehyde TAP/HAP 0.00 0.00E+00 0.011 5.55E-06 0.011 5.55E-06
Acetone Neither 1 374.13 0.19 863.74 0.43 863.74 0.432
Acrolein TAP/HAP 0.00 0.00E+00 0.013 6.58E-06 0.013 6.58E-06
Ammonia TAP 0.00 0.00E+00 8.16 4.08E-03 8.16 4.08E-03
Antimony HAP 5.94 2.97E-03 13.72 6.86E-03 13.72 6.86E-03
Arsenic TAP/HAP 6.82 3.41E-03 17.25 8.63E-03 17.25 8.63E-03
Benzene TAP/HAP 638.23 1 0.32 1,481 0.740 1,481 0.74
Beryllium TAP/HAP 0.00 0.00 2.36 1.18E-03 2.36 1.18E-03
Benzo a rene HAP/TAP 0.09 4.62E-05 3.06E-06 1.53E-09 3.06E-06 1.53E-09
Bis 2-eth lhex I Phthalate HAP 440.16 0.22 1,016.16 0.51 1,016.16 0.508
Butylbenzylphthalate Neither 3.96 1.98E-03 9.15 4.57E-03 9.15 4.57E-03
Cadmium TAP/HAP 3.30 1.65E-03 8.75 4.37E-03 8.75 4.37E-03
Carbon Disulfide TAP/HAP 9.46 4.73E-03 21.85 0.011 21.85 0.011
Chlorine TAP/HAP 286.10 0.14 660.50 0.33 660.50 0.33
Chloroethane HAP 125.45 0.063 289.61 0.14 289.61 0.14
Chloromethane HAP 147.45 0.074 340.41 0.17 340.41 0.17
Chromium VI TAP/HAP 0.00 0.00 1.56 7.80F.-04 1.56 7.80E-04
Chromium HAP 11.22 5.61E-03 27.04 0.014 27.04 0.014
Cobalt HAP 0.46 2.31E-04 6.07 3.04E-03 6.07 3.04E-03
Di Butyl Phthalate HAP 30.81 0.015 71.13 0.036 71.13 0.036
Dieth 1 hthalate Neither 52.82 0.026 121.94 0.061 121.94 0.061
Ethyl Benzene HAP 9.68 4.84E-03 24.54 0.012 24.54 1.23E-02
Formaldehyde TAP/HAP 27.44 0.014 350.99 0.18 350.99 0.18
n-Hexane TAP/HAP 0.00 2.70E-07 4.59 2.30E-03 4.59 2.30E-03
Hydrogen Chloride TAP/HAP 1,329.04 0.66 13,934 6.97 6,137 3.07
Hydrogen Fluoride TAP/HAP 1,057.99 0.53 48,226 24.11 4,885 2.44
Iodomethane HAP 20.47 0.010 47.25 0.024 47.25 0.024
Lead HAP 33.01 0.017 79.59 0.040 79.59 0.040
Manganese TAP/HAP 63.82 0.032 149.59 0.075 149.59 0.075
Mercury TAP/HAP 1.65 8.25E-04 4.94 2.47E-03 4.94 2.47E-03
Naphthalene HAP 14.31 7.15E-03 33.92 0.017 33.92 0.017
Nickel TAP/HAP 15.85 7.92E-03 97.16 0.049 97.16 0.049
Phenol TAP/HAP 18.93 9.46E-03 43.69 0.022 43.69 0.022
Polycyclic Organic Matter TAP 0.00 0.000 18.78 9.39E-03 18.78 9.39E-03
Selenium HAP 50.62 0.025 122.48 0.061 122.48 0.061
Styrene TAP/HAP 4.40 2.20E-03 10.16 5.08E-03 10.16 5.08E-03
Tetrachloroethene TAP/HAP 0.62 3.08E-04 1.42 7.11E-04 1.42 7.11E-04
Toluene TAP/HAP 35.21 0.018 467.54 0.234 467.54 0.234
Total Fluorides TAP 1,692.78 0.85 77,261 38.63 8,016 4.01
X lene TAP/HAP 27.51 1.38E-02 67.26 0.034 67.26 0.034
Total HAPs t 2.24 33.88 8.31
Hydrogen Chloride or
Max HAP(tpy) Hydrogen Fluoride 0.66 24.11 3.07
1.Expected Actual Emissions based on 2021 Wadesboro Air Emission Inventory
2.Reflects emissions with controlled emissions of Hydrogen Chloride,Hydrogen Fluoride,and Total Fluorides,based on the DLA
emission controls on Kilns 1 and 2.
B-1

Potential to Emit from the Brick Tunnel Kiln#1
Source ID-K-1
Triangle Brick Company
Wadesboro,North Carolina
Maximum Potential Production Data
Tans of Fired Brick Produced toll,
Cubic Feet Natural Gas Combussted j@WWfffl'
Gallons Distillate Oil Combusted allans
Gallons Residual OilCombusted goBons
Primary Operating Scenario Secondary rulin Scenario Tertiary Operating Scenario
Pollutant CAS Number NC TAP h/or
CloyFiring(Nat.Gas)" Clay Firing(Nat.Gas)B Distillate Fuel Crmhustion7'"'" Total Distillate Fuel Combustion Residual Fuel Combustion''s'tu Total Emissions Sunmary
HAP. Emission Potential Emission Potential Emission Potentbil >er.5cen. Emission Potential Emission Potential er.Scrn. Potential Potential
F. Emission Rate Facfcrr Emission Rate Factor Emission Rate Emissions Factor Emission Rate I Factor jErrussionMitel Emissions I Emissions Emissions
r
UncontrolledEmissions (ihs ton) llx vt) lbs llon) (Lbs/r) (Ibs ) (lb 1001 alk,n) (I bs ) (Ib 10(0+allon), (Ihs/') (hs r) (It,
) (tons)
TSPt Neither 0.15 38,106 0.15 38,106 2.00 5,356 43,462 2.00 5,356 22.50 20,700 26,056 43,462 21.73
PM-101 Neither 0.74 187,990 0.74 187,990 1.00 2,678 190,668 1.00 2,678 19.50 17,940 20,618 190,668 9533
PM-2.5 Neither 0.74 187,990 0.74 187,990 0.25 670 188,659 025 670 12.70 11,684 12,354 188,659 9433
SO22" Neither 030 76,212 0.30 76,212 71.0 190,142 266354 71.00 190,142 329.70 303,324 493,466 493,466 246.73
NOx2 Neither 0.126 32,009 0.13 32,009 20.0 53,561 85,570 20.00 33,561 47.00 43,240 96,801 96,801 48.40
CO2 Neither 0.577 146,581 058 146,581 5.00 13390 159,971 5.00 13,390 5.00 4,600 17,990 159,971 79.99
VOC' Neither 0.057 14,429 0.057 14,429 0.20 536 14,%S 0.20 536 0.28 257.60 1 79321 14,965 7A8
Total HAPs 2,401 2,401 375.85 2,777 37585 142.02 51787 2,881 1.44
Hydrogen Chloride' 1�4i-01-0 TAP HAP 0.027 6,967 0.027 6,967 N/A 0.00 6,967 N/A O.W N/A 0.W O.WE+00 6,967 3A8
Hydrogen Fluoride° TAP/HAP 0.095 24,113 0.095 24,113 N/A 0.00 24,113 N/A OAO N/A O.W O.WE+W 24,113 12.06
Total Fluoridess i"984-4S N TAP 0.15 38,581 0.15 38,581 0.037 99.99 38,681 0.04 99.89 3.73E-02 34..1 1.34E+02 38,681 1934
Controlled Emissions
Hydrogen Chloride4l -0 TAP/11AP 0.012 3,(168 0.012 3,068 N/A 0.00 3,068 1.21E-02 3,068 N/A 0.00 3,068 3,068 1.53
Hydrogen Fluorides" 76W 39.3 TAP/HAP 9.61E-03 r 2,442 OA1(1 Z442 N/A 0.00 2,442 9.61E-03 2,442 N/A ODO 2,442 2,442 1.12
Total Fluorides' 1698448-8 TAP 1 0.015 r .1,908 0.015 3,908 3.73E-02 99.89 4,008 154E-02 3,908 11 3432 3,942 4,008 100
1.Clay Firing particulate emission factors based on Wadesboro Kiln#2 Stack Test completed September 2016.In the interest of conservatism,the emission factor is twice the tested value.Also it was assumed that PM=PMI0=PM2.5
2.Clay Firing emission factor lased on USEPA/Brick Association of North Carolina sponsored source test completed at Triangle Brick Company's Merry Oaks,North Carolina facility.
2a.Sulfur Content of clay based on mass balance annylsis of raw material.
3.Chromium IV distillate and residual fuel emission rates are Lased on AP-42 Chromium VI emission factor in AP-42 Section 13"Fuel Oil Combustion,"Table 13-11.
4. Uncontrolled clay firing emission factor for Hydrogen Fluoride and Hydrogen Chloride based on source test completed on Kiln#1 in December 2003.DI.A was not operated.
4a.Controlled clay firing emission factor for Hydrogen Fluoride and Hydrogen Chloride lased on source test completed September 2016.In the interest of conservatism,the emission factor is twice the tested value.
5. Emission factor for Total Fluorides is(1.6)x(Hydrogen Fluoride emission factor).The formula used is based on the guidance in AP-42 Section 11.3"Brick and Structure Clay Products,"Table 11.3-4 Footnote F.
6. Emission factors obtained from AP-42 Section 11.3'Brick and Structural Clay Products",Final report,August 1997(unless otherwise noted).
7. Emission factors are obtained from NC DEQ Emission Estimation Spreadsheet for fuel oil combustion(unless otherwise noted).
8. Heat input rating assumed to be 140,O00 Btu/gallon for No.2 fuel oil and 150,000 Btu/gal for No.6 fuel oil.
9.Sulfur content of No.2 fuel oil assumed to be 05%.
10.Sulfur content of No.6 fuel oil assumed to be 2.1%.
from AP-42
from NC TAP
from CAA HAP
tmm AFRO
B-2

Potential to Emit from the Brick Tunnel Kiln#2
Source ID-K-2
Triangle Brick Company
Wadesboro,North Carolina
Maximum Potential Production Data
Totes of Fired Brick Produced WOMERNOWMEENA ton,
Total Cubic Feet Natural Gas Combusted f t'
Total Gallons Distillate Oil Combusted galions
Total Gallons Residual Oil Combust, g,lions
Primary Operating Sconario Seconds CheratingSconam IF TerijamOperatingScenaric,
Pollutant CAS Number NC TAP&/or
Cla Finn Nal.Gas° CIa F nn Nal.Gas° Cislillale Fuel Comtbuslioti'A9 Total Cla Fuin•Nat.Gas° R sidual Fuei CuutbusDonr'°'1° Total Fmrssx ns Sumatary
HAP Emissian Potential Emission Pedential Emission Actual +er.Seem. Emisstort Potential &mission Potcmtial r.Scen. Potential Potential
Factor Emission Rate Factor Emission Fate Factor Emersion Rate Emicvom Factor Emission Rate Factor Emrssion Fate Eutuaumtis Emissions Emissions
(Iboo tcn) ile yr (Its/ton) (Ibs (ib/1000 a llon (Ile/•r) (Ihs/ar) (Ibs ton) Iles r) Ib 10(10 aUun) (Ibs r) lbs r) Ibs) (tons)
Uncontrolled Emissions
TSP' Neither 0.15 38,106 0.15 0.00 2.(1) 5,356 2.68 38,106 19.05
PM-1D' Neither 0.74 187,990 0.15 0.00 1.00 Z678 2,678 187,990 93.99
PM-2.5' Neither 0.74 187,990 0.15 0.00 0.25 669.51 669.51 187,990 93.99
S02u Neither 0.30 76,212 0.30 0.00 71.0 190,142 190,142 190,142 95.07
NO,? Neither 0.13 32,009 0.13 O.OD 20.0 53,%I 53,561 53,561 26.78
COr Neither 0.58 146,581 0.58 O.OD 5.0 13„190 13,390 146,581 73.29
VOC, Neither 0.05680 14,429 0.057 0.00 1 02 1 535.61 1 535.61 14,429 721
Total HAPs 2,401 0.00 375.85 375.85 (loll 0,00 (((Ill 2,704 135
Hydrogen Chloride' -,tA7-fn-at TAP HAP 0.027 6,967 0.027 0.00 N/A 0.00 O.OD 6,%7 3.48
Hydrogen Fluoride' 7(o,439-3 TAP HAP 0.095 24,113 0.095 0.00 N/A 0.00 0.00 24,113 12.06
Total Fluorides' 16984-4R-R TAP 0.15 38,591 0.15 0.00 0.0,17 W99 9989 38,581 19.29
Controlled Emissions
Hydrogen Chlonde" - - TAP/HAP 1 0.012 r 3,068 1 0.012 13,068 N'A o.IXI 3,068 3,068 1.53
Hvdrt en Fluoride" TAP/HAP 9.61E-03 2,442 0.0101 2,442 N/A 0.00 2,442 2442 1.22
Total Fluorides? 16984-48-8 TAP 0.015 r 3,908 1 0,015 1 3,908 0.037 99.89 4,008 40)8 2.00
1.Clay Firing particulate emission factors based on Wadesbora Kiln#2 Stack Test completed October 2016.In the interest of co vatism,the emission factor is twice the tested value.
2.Clay Firing emission factor based on LISEPA/Back Asxx:uation of North Carcdina sponsored source test completed at Triangle Brick Company's Merry Oaks,North Carolina facility.
2a.Sulfur Content of clay basx!d on mass balance anuylsis of raw material.
3.Chromium IV distillate and residual fuel emission rates are hexed on AP-42 Chromium VI emission factor in AP-42 Section 1.3'Fuel Oil Combustion,"Table 1.3-11.
4.Uncontrolled clay firing emission factor for Hydrogen Fluoride and Hydrogen Chloride based on source test completed on Kiln Al in December 2001%.DLA was not operated.
4a.Controlled clay firing emission factor for Hydrogen Fluoride and Hydrogen Chloride based on wwrce test completed September 2016.In the interest of conservatism,the emission factor is twice the tested value.
3.Emission factor for Total Fluorides is(1.6)x(Hydrogen Fluoride emission factor).The formula used is based on the guidance in AP-42 Section 11.3"Brick and Structure Clay Products,"Table 11.3-4 Footnote F.
6.Emission factors obtained from AP-42 Section 11.3"Brick and Structural Clay Products",Final report,August 1997(unless otherwise noted).
7.Emission factors are obtained from NC DBQ Emission Estimation Spreadsheet for fuel oil combustion(unless otherwise noted).
R.Heat input rating assumed to he 140,OM Btu/pIlnn for No.2 fuel nil and 150,(M Btu/gal for No.6 fuel nil.
9.Sulfur content of Nat fuel oil asstimed to be 0.5%.
10.Sulfur content of No.6 fuel oil assumed to be 2.1%.
from AP-42
frcmt NC TAP
from CAA HAP
tnmt AERO
6-3

Potential Formaldehyde Emissions from Natural Gas
Combustion in the Brick Tunnel Kilns
Source IDs K-1 and K-2
Triangle Brick Company
Wadesboro, North Carolina
Fuel Combustion Data
Natural Gas Combustion-Kiln#1: 364,007,767 ft3
Natural Gas Combustion-Kiln#2: 364,007,767 ft3
Formaldehyde Emission Factors: 0.075 lb/10E06 ft�
Emission Calculations-Kiln#1
Formaldehyde(lb/yr) = 364007766.990291 ft3 x 0.075 lb/10E06 ft3
27.30 lb formaldehyde/yr
Emission Calculations-Kiln#2
Formaldehyde(lb/yr) = 364007766.990291 ft3 x 0.075 lb/1OE06 ft3
27.30 lb formaldehyde/yr
Total Formaldehyde Emissions-Kiln#1&Kiln#2
Formaldehyde(lb/yr) = 54.60 lbs Formaldehyde/yr
1.NCDAQ Natural Gas Combustion Emissions spreadsheet
B-4

Potential GHG Emissions from the Brick Tunnel Kilns and Rotary Sand Dryer
Source IDs K-1, K-2 and SD-1
Triangle Brick Company
Wadesboro, North Carolina
Maximum Annual Fuel Throughputs
Distillate Residual
Emission Source Natural Gas Oil Oil
sc al al
Brick Tunnel Kiln#1 0 1.692,343 920,000
Brick Tunnel Kiln#2 0 2,678,057 0.00
iRotary Sand Dryer 2.551,456
High Heat Values(From 40 CFR 98 Subpart C,Table C-1) Global Warming Potentials(40 CFR 98 Table A-1)
MMBtu/scf CO2 1
Natural Gas 0.001026 CH4 25
N2O 298
MMBtu/gal
Distillate Fuel Oil No.2 0.138
Residual Fuel Oil No.6 0.150
Emission Factors(From 40 CFR 98 Subpart C,Table C-1) Emission Factors(From 40 CFR 98 Subpart C,Table C-2)
kg CO2/MMBtu kg CH4/MMBI N2O/MMBtu
Natural Gas 53.06 Natural Ga 0.001 0.0001
Petroleum 0.003 0.0006
kg CO2/MMBtu
Distillate Fuel Oil No.2 73.96
Residual Fuel Oil No.6 75.10
Greenhouse Gas Emissions by Fuel Source
Natural Gas Emissions Distillate Oil Emissions Residual Oil Emissions
CH4 N2O CO2 CH4 N2O CO2 CH4 N2O
Emission Source CO2 (metric (metric (metric (metric (metric (metric (metric (metric
metric tonnes tonnes) tonnes) tonnes) tonnes) tonnes) tonnes tonnes) tonnes
Brick Tunnel Kiln#1 0 0.00 0.00 17,273 0.70 0.14 10,364 0.41 0.083
Brick Tunnel Kiln#2 0 0.00 0.00 27,334 1.11 0.22 0.00 0.00 0.00
Rotary Sand Dryer 139 2.62E-03 2.62E-04
Total Emissions 139 0.00 0.000 44,606 1.81 0.36 10,364 0.41 0.083
Greenhouse Gas Emissions by Source
CH4 N2O CO2e
Emission Source CO2 (metric (metric (metric
metric tonnes tonnes) tonnes tonnes
Brick Tunnel Kiln#1 27,637 1.11 0.223 27,731
Brick Tunnel Kiln#2 27,334 1.109 0.2217 27,427
Rotary Sand Dryer 138.90 2.62E-03 2.62E-04 139.04
Total Emissions 1 55,109 2.23 0.445 55,297
Total greenhouse gas emissions does not exceed 25,000 metric tonnes per year.
B-5

1
Potential HAP and TAP Emissions from the Rotary r Sand Dryer
Source ID SD-1
Triangle Brick Company
Wadesboro,North Carolina
Production Data
Cubic Feet Natural Gas Combusted 2,551,456 ft;
CAS NC TAP&/or Natural Gas Fuel Combustion'
Pollutant Number HAP Emission Potential Total Potential
Factor Emission Rate Emissions
Ib/MMscf) 1 ) (tons)
1,1,1 Trichloroethane 71-55-6 TAP/HAP N/A 0.00 0.00E+00
1,4 Dichlorobenzene 106-46-7 TAP/HAP N/A 0.00 0.00E+00
2-Hexanone MIBK 591-78-6 TAP/HAP N/A 0.00 0.00E+00
Ammonia 7664-41-7 TAP 3.20E+00 8.16 4.08E-03
Antimony SBC-Other HAP N/A 0.00 0.00E+00
Arsenic ASC-Other TAP/HAP 2.00E-04 5.10E-04 2.55E-07
Benzene 71-43-2 TAP/HAP 2.10E-03 5.36E-03 2.68E-06
Benzo a ene 50-32-8 HAP/TAP 1.20E-06 3.06E-06 1.53E-09
Beryllium 744041-7 TAP/HAP 1.20E-05 3.06E-05 1.53E-08
Bis 2-ethylhex 1 Phthalate 117-81-7 HAP N/A 0.00 0.00E+00
Cadmium 7440-43-9 TAP/HAP 1.10E-03 2.81E-03 1.40E-06
Carbon Disulfide 75-15-0 TAP/HAP N/A 0.00 0.00E+00
Chlorine 7782-50-5 TAP/HAP N/A 0.00 0.00E+00
Chloroethane 75-00-3 HAP N/A 0.00 0.00E+00
Chloromethane 74-87-3 HAP N/A 0.00 0.00E+00
Chromium VI NSCR6-Oche TAP/HAP 1.40E-03 3.57E-03 1.79E-06
Chromium CRC-Other HAP N/A 0.00 0.00E+00
Cobalt COC-Other HAP 8.40E-05 2.14E-04 1.07E-07
Di Butyl Phthalate 84-74-2 HAP N/A 0.00 0.00E+00
Eth-1 Benzene 100-414 HAP N/A 0.00 0.00E+00
Formaldehyde 50-00-0 TAP/HAP 7.50E-02 0.19 9.57E-05
Hexane 110-54-3 TAP HAP 1.80E+00 4.59 2.30E-03
Hydrogen Chloride 7647-01-0 TAP/HAP N/A 0.00 0.00E+00
Hydrogen Fluoride 7664-39-3 TAP/HAP N/A 0.00 0.00E+00
Iodomethane 74-88-4 HAP N/A 0.00 0.00E+00
Lead PBC-Other' HAP 5.00E-04 1.28E-03 6.38E-07
Manganese MNC-Other TAP/HAP 3.80E-04 9.70E-04 4.85E-07
Mercury 7439-97-6 TAP/HAP 2.60E-04 6.63E-04 3.32E-07
Naphthalene 91-20-3 HAP 6.10E-04 1.56E-03 7.78E-07
Nickel 7440-02-0 TAP/HAP 2.10E-03 5.36E-03 2.68E-06
Phenol 108-95-2 TAP/HAP N/A 0.00 0.00E+00
Selenium SEC HAP 2.40E-05 6.12E-05 3.06E-08
Styrene 100-42-5 TAP/HAP N/A 0.00 0.00E+00
Tetrachloroethene 127-184 TAP/HAP N/A 0.00 0.00E+00
Toluene 108-88-3 TAP/HAP 3.40E-03 8.67E-03 4.34E-06
X lene 1330-20-7 TAP/HAP N/A 0.00 0.00E+00
1. Emission factors are obtained from NC DEQ Emission Estimation Spreadsheet for natural gas combustion.
from AP-42
from NC TAP
from CAA HAP
from AERO
B-6

Potential Emissions from the Crushing,Grinding and Scre
ening
Source IDs PC1-PC10, CG1-CG55
Triangle Brick Company
Wadesboro, North Carolina
Emission
Potential Potential Potential
Source Pollutant 1 Factor Units Throughput Emission Emission
(tons)' Rate(lb/yr) Rate(torVyr)
PM2.53 5.90E-02 lbs/ton 668,526 39,443 19.72
Primary Crushing4 PM10 5.90E-02 lbs/ton 668,526 39,443 19.72
PM 5.90E-02 lbs/ton 668,526 39,443 19.72
PM2.53 0.0023 lbs/ton 668,526 1,538 0.77
Grinding&Screening pMlo 0.0023 lbs/ton 668,526 1,538 0.77
PM 0.025 1 lbs/ton 668,526 16,713 8.36
1.Emission factor based on AP-42 Section 11.3"Brick and Structural Clay Product
Manufacturing,Final Report",August 1997.
2.Throughput based on multiplying fired brick production by 5.0/3.8 to account for moisture content of raw material.
3.PM2.5(and PM for primary crushing)emission factors not included in AP-42.Assumed emission factors=PM,()emission
factor.
4.PM-10 emission factor for primary crushing in AP-42 is based on a test on a primary crusher with a fabric filter control.
Assumed control had 99%efficiency.Triangle Brick's primary crusher has no control,therefore the AP-42 emission factor is
divided by(1-.99).
B-7

I
Potential Emissions of Acetaldehyden and Acrolein from Natural Gas Combustion
in the Brick Tunnel Kilns and Rotary Sand Dryer
Source IDs K-1,K-2,and SD-1
Triangle Brick Company
Wadesboro,North Carolina
Natural Gas Combusted
K-1 364,007,767 ft3
K-2 364,007,767 ft3
SD-1 2,551,456 fe
Emission Rate l
Tots
Emission Factors Pollutant (lb/I06 ft) ( sJyr lb ) Emissions
WADEKI WADEK2 SD-1 (tPY)
Acetaldeh de ,T I 1.52E-05 5.53E-03 5.53E-03 3.88E-05 5.55E-06
Acrolein , ** 1.80E-05 6.55E-03 6.55E-03 4.59E-05 6.58E-06
1.Acrolein and Acetaldehyde emissions are calculated using NCDAQ Natural Gas Combustion Emissions spreadsheet emission
factors.Because these contaminants are not listed in AP-42 Chapter 1.4,they are listed here separately.
B-8