AQ_F_1900009_20210729_PRMT_PmtRvw

NORTH CAROLINA DIVISION OF AIR QUALITY Region: Raleigh Regional Office
County: Chatham
Application Review NC Facility ID: 1900009
Inspector's Name: Jeff Harris
Issue Date: July 29,2021 Date of Last Inspection: 01/14/2021
Compliance Code: 3 1 Compliance- inspection
Facility Data Permit Applicability(this application only)
Applicant(Facility's Name): General Shale Brick, Inc.- Moncure Facility SIP:
NSPS:
Facility Address: NESHAP:
General Shale Brick, Inc. - Moncure Facility PSD:
300 Brick Plant Road PSD Avoidance:
Moncure,NC 27559 NC Toxics:
112(r):
SIC: 3251 /Brick And Structural Clay Tile Other:
NAICS: 327121 /Brick and Structural Clay Tile Manufacturing
Facility Classification: Before: Title V After: Synthetic Minor
Fee Classification: Before: Title V After: Synthetic Minor _
Contact Data Application Data
Facility Contact Authorized Contact Technical Contact
Application Number: 1900009.2113
J. Warren Paschal Kevin Ham J. Warren Paschal Date Received: 03/23/2021
Manager of VP Engineering& Manager of Application Type: Renewal/Modification
Environmental Research Environmental Application Schedule: State
Compliance [phone] Compliance Existing Permit Data
[phone] 3015 Bristol Highway [phone] Existing Permit Number: 043841T39
300 Brick Plant Road Johnson City,TN 37601 300 Brick Plant Road Existing Permit Issue Date: 01/13/2017
Moncure,NC 27559 Moncure,NC 27559 Existing Permit Expiration Date: 12 31 2021
Total Actual emissions in TONS/YEAR:
CY S02 NOX VOC CO PMIO Total HAP Largest HAP
jHydrogen chloride(HCI)j
2016 0.68 26.61 3.88 67.68 52.85 3.51 2.02
2017 0.83 32.39 4.57 82.42 64.42 4.55 2.17
2018 0.85 33.30 4.68 84.70 66.33 4.67 2.23
2019 0.75 29.22 4.19 74.32 58.11 3.31 1.71
2020 0.6 23.4 3.49 59.55 46.55 3.01 1.37
Review Engineer: Sindy Huang Comments/Recommendations:
Issue 04384/R40
Review En 'neer's Signature: Date: Permit Issue Date: 07/29/2021
lot 25lZvZI Permit Expiration Date: 06130/2029
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1. Purpose of Application:
General Shale Brick, Inc. - Moncure Facility(General Shale)produces various sizes and styles of bricks at
their Moncure facility. Clay is transported to the plant from nearby mines,processed to a fine texture,and
then extruded into bricks. The bricks then are texturized prior to entering one of four brick kilns. All the
kilns have four distinct zones:the drying zone,the preheating zone,the firing zone,and the cooling zone.
After exiting the kilns,the bricks are packaged for shipping.
The purpose of this application is a renewal and modification. The facility requests to change its facility
classification of Title V to synthetic minor. The facility also requests to remove its coal processing system
(coal crusher and associated bagfilter),grinding and screening operations(one impact crusher,two scalping
screens,two hammermills, four finishing screens,and seventeen conveyors),block plant(flyash silo and
associated bin vent filter, cement silo and associated bin vent filter,and batch mixer and associated
bagfilter),and sand silo system and associated bin vent filter.
Additionally,the facility requests to inactivate the brick processing lines 1 and 2(two wood/natural gas-
fired brick tunnel kilns and one rotary sawdust dryer and two associated simple cyclones operating in
parallel),the wood fuel 1 sawdust system(two 8 x 8 screens and two associated dust collector,a cyclone, a
hammermill and associated cyclone, sawdust silo and associated bin vent filter, surge hopper and
associated bin vent filter,transfer screw conveyor and screw feed conveyor,and enclosed conveyor),and
two texturizing operations for Lines 1 and 2 and associated bagfilter.
From the insignificant list,the facility requests to remove the coal pile,coal hopper,and sand conveyor.
Additionally,the facility requests to inactivate the wood receiving,non-pneumatic handling and conveying,
and storage operations,the screened clay conveying and handling operation for kiln 1 and 2,the brick dryer
associated with kiln 1,and the brick dryer associated with kiln 2.
The inactive sources are equipment that are currently non-operational;however,once these sources are
repaired,the facility intends to operate them again. Potential emissions from these sources are included in
the facility-wide Title V emissions in Section 7.
2. Application Chronology:
March 23,2021 RRO received an air permit renewal and modification application from General
Shale Brick, Inc. -Moncure Facility. The application included the necessary
forms,calculations,and Title V compliance certification but did not include the
$400 modification fee.
April 2,2021 Ms. Dena Pittman, Permit Coordinator,sent an acknowledgement letter stating
the application was not complete because of the missing fee and was not
accepted for processing.
April 16,2021 Mr. Warren Paschal,General Shale's Manager of Environmental Compliance,
sent a letter enclosed with the$400 application fee.
THIS ACTION STARTED THE CLOCK.
Ms. Pittman also assigned this permit to me,Sindy Huang,on this day.
June 15,2021 I called Mr. Paschal about the operational status of the equipment the facility
wanted to inactivate. Mr. Paschal confirmed that the equipment to be inactivated
had not run since 2009,was in disrepair,and would take around a year to make
operational again.
June 21,2021 The facility submitted their emission inventory via AERO.
June 28,2021 The RRO received two paper copies of the facility's emission inventory.
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July 7,2021 I sent an email to Mr. Paschal asking for the square footage area of the bagfilters
for the wood fuel/sawdust system and the coatings dryer,which were currently
in the permit using air-to cloth ratio instead of square feet of filter area.
CLOCK TURNED OFF.
July 8,2021 Mr. Paschal replied to my email with the requested information:
CD-SD-DC I --241 ft2
CD-SD-DC2 -241 ft2
CD-SD-BV I —90 ft2
CD-SD-BV2—90 ft2
CD-CD8BF-- 1950 ft2
CLOCK TURNED ON.
July 9,2021 1 sent an email to Mr. Paschal asking if certain bagfilters were in parallel.
CLOCK TURNED OFF.
July 13,2021 Mr. Paschal replied to my email with the requested information.
CLOCK TURNED ON.
July 16,2021 Draft permit sent to facility for review.
CLOCK TURNED OFF.
July 28,2021 Comments for draft permit received.These comments have been incorporated
into the permit except for requested revisions to NSPS Subpart 000.
CLOCK TURNED ON.
3. New Equipment/Change in Emission and Regulatory Review:
The purpose of this application is a renewal and modification. The facility requests to change its facility
classification of Title V to synthetic minor.The application requested the removal of non-operational
equipment no longer located at the facility;however,non-operational sources that are still located at the
facility shall be listed as inactive. Inactive sources could become operational and shall remain on the
permit. If any inactive sources become operational,the Permittee shall record the date each source becomes
operational and any resultant emissions.
The following table shows the changes to the permitted equipment list for this modification. Items struck
thFOUgh were removed from the permit, items in bold were added,and items italicized are inactive.
Emission Source Emission Source Description Control Device Control Device Description
ID No. ID No.
Brick Tunnel Kilns
BRICK PROCESSING LINE 3 —BRICKHAVEN PLANT#25
ES-K3K P498 CD-K3DLA Dry limestone adsorber
One natural gas/propane-fired brick
MAG tunnel kiln(25.9 million Btu per hour
heat input and 20.55 tons per hour
maximum fired brick production rate)
A08
heat input and 20.55 tons per-how
ES-K3D1,ES-K3D2,and Three natural gas/propane-fired brick N A N A
ES-K3D3 dryers(4.43 million Btu per hour heat
input)
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Emission Source Emission Source Description Control Device Control Device Description
ID No. ID No.
BRICK PROCESSING LINE 4—BRICKHAVEN PLANT#25
ES-K4K PPS CD-K4DLA Dry limestone adsorber
02P 1 109 Case By Cas One natural gas/propane-fired brick
MAG tunnel kiln(25.9 million Btu per hour
heat input and 20.55 tons per hour
maximum fired brick production rate)
A9S
One eeaWatur-al gaS�PFOPEIHe fired brick
tunnel kiln(25.9 million Btu per-hou
heat input and 20.55 tons per how
ES-K4DI,ES- K4132, Three natural gas/propane-fired brick N A N A
and ES-K4D3 dryers(4.43 million Btu per hour heat
input)
SS Coal Coal eFushe CD Coal One bagfilteF(4.7:1 air-to
C-let�
Coatings Dryer
ES-CD-8 One natural gas-fired rotary drum CD-CDBBF One bagfilter"."��air-to
coatings dryer(250,000 Btu per hour heat eleth Fatie)(1,950 square feet
input;3.45 tons per hour drying capacity) of filter area)
Clay Handling Equipment(200 tons per hour maximum capacity)
F-PC Primary crusher NIA NIA
(NSPS)
F-SS I and F-SS2 Two scalping screens N A N A
(NSPS)
F-SGS Secondary crusher N A N A
(NSPS)
F-FS1 and F-FS2 Two single deck screens N A N A
(NSPS)
F-FS3,F-FS4,and F-FS5 Seven finishing screens N A N A
through F-FS9
(NSPS—F-FS3 and
F-FS4 only)
F-FC4 and F-FC5 Two finishing conveyors#4 and#5 N A N A
(NSPS)
F-C-CFBH Intersite conveyor N/A N A
(NSPS)
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Emission Source Emission Source Description Control Device Control Device Description
ID No. ID No.
F C14 SS! and Two sealping seFeens N/A WA
F GH 8882
C14 ul and F r14_142 Two hammeFmills WA NM
C C14 FS 1 C Q4 F92 C WA, NA
Cu FS3 and r GH FS4
CF GH FC One feedF C14 SSr-C One scalping,
C C14 D1 and C GH D7
e
C !�C
F-c4 BG OMe:e.eFSi
C f`�-c 4 CFG One Br-iekhaven-,
C C14 T 1 and C CH T7 One-Cape--Fear-
tailings,
C fi--C 14 HFC2
feed,
C r,--C HrTrc2
F Cu SF-C 1 ❑ru
8FG2 F Cu SFG3 and
C Q SKA
Four-s n feed
Texturizing Operations
ES-CR7 Texturizing operation for Line 3 CD-CR713171, Bagfilter(6,096 square feet
CD-CR7BF2 of filter area)in parallel with
bagfilter(4,062 square feet of
filter area)
ES-CR8 Texturizing operation for Line 4 CD-CR7BF3 bagfilter(3,040 square feet of
filter area)
Sleek Plant
CC BP CepCOMeRt !'n�2 One bin N,ent filte..(22 7
CCzS BP B R !`ll�� One bagfilter(535 square F er
/ Sand Sfle-SyStCnf
storage
Rumbler System
ES-RUMBLE Rumbler system CD-RUMBLE I One bagfilter(2,292 square
feet of filter area)
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Emission Source Emission Source Description Control Device Control Device Description
ID No. I I ID No.
INACTIVE EMISSION SOURCES
(Initial start-up and resultant emissions shall be recorded.Refer to Condition A.13)
Brick Tunnel Kilns
BRICK PROCESSING LINES I AND 2—CAPE FEAR PLANT 924
ES-KI and ES-K2 92-D Two wood/natural gas-fired brick tunnel NIA NIA
1109 Case a.,Gas kilns(20.3 million Btu per hour heat
AAA(INACTIVE) input and 13.7 tons per hoar fired brick
production rate)
ES-WD1,2(INACTIVE) One rotary sawdust dryer(5.59 tons per CD-CI and CD- Two simple cyclones
hour drying capacity;heated by recycle C2 operating in parallel(89
heat from kilns 1 and 2 with natural gas inches in diameter each)
used as a supplemental fuel)
Wood FueUSawdust System
ES-WFS-SD-SCI and Two 8 x 8 screens CD-SD-DC1 Two .
ES-WFS-SD-SC2 and CD-SD-
(INACTIVE) DC2 reVeetivelp}bagflters(241
square feet of filter area
each)installed one each
ES-WFS-SD-CYC Cyclone CD-SD-DC2 Lheeeter{8 96 1i�to
(INACTIVE) eleth retie)Bagrilter(241
square feet of filter area)
ES-WFS-SD-HM Hammermill CD-WFS-SD- Cyclone(42 inches in
(INACTIVE) CYC and CD- diameter)and dust collector
SD-DC2 (241
square feet of filter area)
ES-WFS-SD-SDS Sawdust silo CD-SD-BVI One bin vent filter(4.44
(INACTiVE) fe eleth+wtie)(90 square feet
of filter area)
ES-WFS-SD-SH Surge hopper CD-SD-BV2 One bin vent filter(4114-air
(INACTiVE) to eleth ratio) (90 square feet
of filter area)
ES-WFS-SD-CVI and Transfer screw conveyor and screw feed CD-SD-DCI Dirsi eelleeFe+ (8-.;Z!.--1 ah.to
ES-WFS-SD CV2 conveyor eletla ratio)Bagfilter(241
(INACTIVE) square feet of filter area)
ES-WFS-SD-CV3 Enclosed conveyor NIA NIA
(INACTIVE)
Terturizing Operations(INACTIVE)
ES-CR5 and ES-CR6 Two texturizing operations for Lines I CD-CR6BF One bagftlter(6,096 square
(INACTIVE) and 2 feet offrlter area)
Inactive Source Emissions Review:
The following emissions are for the inactive sources and have been calculated based on the emission
factors from the emission inventory.
Brick Processing Lines 1&2: Emissions are based on the emission factors provided in the emission
inventory and throughput based on the Cape Fear Plant process weight rate during the June 2006 testing
(22.3 tons per hours each).
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Pollutant Emission Factor Title V
lb/ton fired bricks produced tpy
PM 0.675 65.9
PM-10 0.675 65.9
PM-2.5 0.675 65.9
NOx -- --
CO .037 3.61
S02 0.18 17.6
VOC 0.344 33.6
H F 0.23 22.5
HCI 1 0.17 16.6
Wood Fuel/Sawdust System: Emissions are based on the uncontrolled emission factors for the control
devices provided in the emission inventory.
Pollutant CD-SD-DC1 CD-SD-DC2 CD-SD-BV1 CD-SD-BV3 Total
lb/hr lb/hr lb/hr lb/hr
PM 18.0 20.1 3.4 3.4 (tpy)
Total 157,680 176 076 29,784 29,784 196.66
Two Texturizing Operations for Lines 1 and 2: Emissions are based on the emission factors provided in
the emission inventory and throughput based on the Cape Fear plant process weight rate during the June
2006 testing(22.3 tons per hours each).
Pollutant Emission Factor Total
lb/ton fired bricks produced tpy
PM 0.0036 0.35
The inactive source emissions from above have been summarized in the table below.These emissions are
uncontrolled emissions.
Brick Processing Wood Fuel/ Texturizing Operations Total
Pollutant Lines 1&2 Sawdust System for Lines 1&2
tpY tpy tpy tpy
PM 65.9 196.66 0.35 262.61
PM-10 65.9 196.66 0.35 262.61
PM-2.5 65.9 196.66 0.35 262.61
NOx -- --- -- --
CO 3.61 --- -- 3.61
S02 17.6 --- -- 17.6
VOC 33.6 --- -- 33.6
H F 22.5 --- -- 22.5
HCI 16.6 --- -- 16.6
Active Source Emission Review:
The active source emissions have been provided by the facility and are for controlled emissions only.
Pollutant Total ACTIVE Emissions-
tpy
PM 84.91
PM-10 64.54
PM-2.5 64.18
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Pollutant Total ACTIVE Emissions
tpy
NOx 80.76
CO 87.85
S02 5.03
VOC 9.72
H F 0.01
HCI 4.73
Reaulatory Review:
213.0202,PERMIT RENEWAL AND EMISSION INVENTORY REQUIREMENT—The Permittee,
at least 90 days prior to the expiration date of this permit,shall request permit renewal by submitting the
signed A form,air pollution emission inventory report(with Certification Sheet)documenting air pollutants
emitted for the 2028 calendar year.
• This rule is applicable facility-wide.
• Compliance with this regulation will be determined by the timely submittal of the renewal request
and emission inventory.
213.0515,PARTICULATE CONTROL REQUIREMENT—Per"Particulates from Miscellaneous
Industrial Processes,"particulate matter emissions from the emission sources shall not exceed allowable
emission rates below:
E=4.10 *(P)0.67 for P<=30 tonslhr,or
E=55 * (P)"I-40 for P>30 tonslhr
• This rule is applicable to all PM emission sources in the permit. The emission rates were evaluated
in previous review and the proper use and maintenance of control devices shall ensure compliance.
213.0516,SULFUR DIOXIDE CONTROL REQUIREMENT— Per"Sulfur Dioxide Emissions from
Combustion Sources,"sulfur dioxide emissions from the combustion sources shall not exceed 2.3 pounds
per million Btu heat input.
• This is applicable to all combustion sources:
• Two wood/natural gas-fired brick tunnel kilns(20.3 million Btu per hour heat input and
13.7 tons per hour fired brick production rate)(ID No. ES-K1 and ES-K2).
a One natural gas/propane-fired brick tunnel kiln(25.9 million Btu per hour heat input and
20.55 tons per hour maximum fired brick production rate)(ID No. ES-K3K)and
associated Three natural gas/propane-fired brick dryers(4.43 million Btu per hour heat
input)(ID No. ES-K3D1, ES-K3D2,and ES-K3133).
o One natural gas/propane-fired brick tunnel kiln(25.9 million Btu per hour heat input and
20.55 tons per hour maximum fired brick production rate)(ID No. ES-K4K)and
associated Three natural gas/propane-fired brick dryers(4.43 million Btu per hour heat
input)(ID No. ES-K4131, ES- K4132,and ES-K4133).
o One natural gas-fired rotary drum coatings dryer(250,000 Btu per hour heat input;3.45
tons per hour drying capacity)(ID No. ES-CD-8).
• Compliance is expected as natural gas and propane are naturally low in sulfur.
2D.0521,VISIBLE EMISSIONS CONTROL REQUIREMENT--Per"Control of Visible Emissions,"
visible emissions from the emission sources manufactured as of July 1, 1971,shall not be more than 40
percent opacity and manufactured after July 1, 1971,shall not be more than 20 percent opacity.
• The 40%visibility requirement is applicable to the texturizing operation for Line 1 (ID No. ES-
CR5(INACTIVE)),the texturizing operation for Line 2(ID No. ES-CR6(INACTIVE)),the
wood/natural gas-fired tunnel brick kiln(20.3 million Btu per hour heat input and 13.7 tons per
hour fired brick production rate)(ID No. ES-K1 (INACTIVE)),the wood/natural gas-fired tunnel
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brick kiln(20.3 million Btu per hour heat input and 13.7 tons per hour fired brick production rate)
(ID No. ES-K2(INACTIVE)),and the sawdust dryer(ID No. ES-WD1,2(INACTIVE)).
• All other equipment falls under the 20%visible emissions standard.
• Compliance to be determined during inspection.
2D.0524, "NEW SOURCE PERFORMANCE STANDARDS"—The Permittee shall limit visible
emissions for the applicable sources to below the specified limits.
• This rule is applicable to the clay handling equipment(primary crusher(ID No. F-PC),two
scalping screens(ID Nos. F-SS1 and F-SS2), secondary crusher(ID No. F-SGS),two single deck
screens(ID Nos. F-FS1 and F-FS2),two finishing screens(ID Nos. F-FS3 and F-FS4),two
finishing conveyors#4 and#5 (ID Nos. F-FC4 and F-FC5),and intersite conveyor(ID No. F-C-
CFBH)).
• Compliance to be determined during inspection.
2D.0535,NOTIFICATION REQUIREMENT In the case of a source of excess emissions that last for
more than four hours and that results from a malfunction,a breakdown of process or control equipment or
any other abnormal conditions, shall notify the Director or his designee of any such occurrence by 9:00
a.m. Eastern time of the Division's next business day of becoming aware of the occurrence.
• This rule is applicable facility-wide.
• Compliance to be determined during inspection.
2D.0540, FUGITIVE DUST CONTROL REQUIREMENT—Per"Particulates from Fugitive Dust
Emission Sources,"the Permittee shall not cause or allow fugitive dust emissions to cause or contribute to
substantive complaints or excess visible emissions beyond the property boundary.
• This rule is applicable facility-wide.
• Compliance to be determined during inspection.
2D.0605,COMPLANCE CERTIFICATION—Per"Compliance Certification,"within 45 days of the
issuance date of permit 04384R40,the Permittee shall submit a compliance certification to the DAQ and to
the EPA. The compliance certification shall encompass the current calendar year from January Ist through
the effective date of this permit and be certified by a responsible official with all federally-enforceable
terms and conditions in the Title V permit.
• This rule is applicable facility-wide.
• Compliance to be determined with the timely receipt of the compliance certification.
213.1100,TOXIC AIR POLLUTANT EMISSIONS LIMITATION AND REPORTING
REOUIREMENT--Per"Control of Toxic Air Pollutants,"and in accordance with the approved
application for an air toxic compliance demonstration,the permit limits shall not be exceeded.
• This rule is applicable to the four brick tunnel kilns(ID No. ES-K1, ES-K2, ES-K3K,and ES-
K4K). In the most recent compliance inspection,the facility requested that the limestone feeder
setting of the DLAs(ID Nos.CD-K3DLA and CD-K4DLA)shall be maintained at or above 30
pounds per hour averaged over a 24-hour block period instead of the currently noted 1 10 pounds
per hour. Based on a review of the modeling analysis summaries,this correction should be made
to correct this error.
• Compliance is expected as long as the facility operates as specified according to the modeling
conditions.
2D.1109,CASE BY CASE MACT FOR BRICK MANUFACTURERS—The Permittee must regularly
inspect the dry lime absorbers and record the results of their findings.The Permittee must also submit a
semi-annual report documenting any deviations.
• This condition has been removed from the permit because it is applicable to Title V facilities only.
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2D.1806,CONTROL AND PROHIBITION OF ODOROUS EMISSIONS—The Permittee shall not
operate the facility without implementing management practices or installing and operating odor control
equipment sufficient to prevent odorous emissions from the facility from causing or contributing to
objectionable odors beyond the facility's boundary.
• This rule is applicable facility-wide.
• Compliance to be determined during inspection.
2Q.0315, LIMITATION TO AVOID 15A NCAC 20.0501 —Pursuant to 15A NCAC 2Q.0315
"Synthetic Minor Facilities"the facility has the potential to exceed 100 tpy of PM 10. The facility must
perform recordkeeping of the control device inspection and maintenance and provide records upon request
(See the specific requirements for the cyclone and bagfilters below). The inactive sources as noted in the
equipment table emit HAPs(specifically HCI and HFI)that could exceed the 10 ton per year individual
threshold and/or the 25 ton per year total threshold. The Permittee will be required to notify the DAQ of
the date of startup of any of the sources marked as inactive and begin tracking the emissions from the
source.
• This rule is applicable facility-wide and to the equipment marked as inactive in the permitted
equipment table.
• Compliance with this regulation will be determined by checking the control device logbooks,and
for the inactive emission sources,the start-up notifications and resultant emissions during the
inspection.
2Q.0315,CYCLONE REQUIREMENTS--Pursuant to 15A NCAC 2Q.0315 "Synthetic Minor
Facilities"shall perform at least an annual inspection for each particulate collection device system with
inspection dates and actions taken recorded in a logbook.
• This rule is applicable to the rotary sawdust dryer(ID No. ES-WD1,2),the cyclone(ID No. ES-
WFS-SD-CYC),and the hammermill(ID No. ES-WFS-SD-HM).
• Compliance with this regulation will be determined by checking inspection and maintenance
records for cyclones during air quality compliance inspections.
2Q.0315,FABRIC FILTER REQUIREMENTS— Pursuant to 15A NCAC 2Q .0315 "Synthetic Minor
Facilities"shall perform at least an annual internal inspection for each particulate collection device system
with inspection dates and actions taken recorded in a logbook.
• This rule is applicable to the rotary sawdust dryer(ID No. ES-WD1,2),the wood fuellsawdust
handling system(two 8 x 8 screens(113 No. ES-WFS-SD-SC1 and ES-WFS-SD-SC2),a cyclone
(ID No. ES-WFS-SD-CYC),a hammermill(ID No. ES-WFS-SD-HM),sawdust silo(ID No. ES-
WFS-SD-SDS),surge hopper(ID No. ES-WFS-SD-SH),transfer screw conveyor and screw feed
conveyor(ID Nos. ES-WFS-SD-CV1 and ES-WFS-SD CV2)),the rotary drum coatings dryer
(ID No. ES-CD-8),the four texturizing operations(ID No. ES-CRS, ES-CR6, ES-CR7, ES-
CR8),and the rumbler system(ID No. ES-RUMBLE).
• Compliance with this regulation will be determined by checking inspection and maintenance
records for bagfilters during air quality compliance inspections.
2Q.0711,TOXIC AIR POLLUTANT EMISSIONS LIMITATION REQUIREMENT the Permittee
has made a demonstration that facility wide potential emissions do not exceed the Toxic Permit Emission
Rates(TPERs)as listed in 15A NCAC 2Q .0711 for the following toxic air pollutants:
Hourly Limit pollutants: Bromine,Creosol(mixed isomers), Dichlorobenzene(p), 1,4-,Ethyl
mercaptan, Formaldehyde, Hexane isomers(except n-hexane), MIBK(methyl isobutyl ketone), Methyl
mercaptan,Nitrobenzene, Pentachlorophenol, Styrene
Daily Limit Pollutants: Carbon disulfide, Hexane,n-, MIBK(methyl isobutyl ketone), Manganese&
compounds,Nitrobenzene,Pentachlorophenol
Annual Limit Pollutants: Chromium(VI)Non-Specific Compounds,as Chrom(VI)(Component
CRC), PCB(polychlorinated biphenyls)
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• This rule is applicable facility-wide.
• Compliance is expected as long as the facility operates as specified according to the modeling.
Control Device Review:
No control devices were added or modified with this permit modification,so an emissions review is not
necessary.
However,the descriptions for some of the control devices have been updated to show the filter area instead
the air-to cloth ratio. The dust collector filter sizes were provided by the facility.
Control Device OLD Control Device NEW Control Device
ID Description Description
CD-SD-DC I Dust collector Bagfilter
8.06:1 air to cloth ratio 241 square feet of filter area
CD-SD-DC2 Dust collector Bagfilter
8.06:1 air to cloth ratio 241 square feet of filter area
CD-SD-BV I One bin vent filter One bin vent filter
4.44:1 air to cloth ratio 90 s uare feet of filter area
CD-SD-BV2 One bin vent filter One bin vent filter
4.44:1 air to cloth ratio 90 s uare feet of filter area
CD-CD8BF One bagfilter One bagfilter
2.05:1 air to cloth ratio 1,950 square feet of filter area
Insignificant Sources:
The facility requests to remove the coal pile(ID No. 1-F-Coal-CP),coal hopper(ID No. 1-F-Coal-CH)and
sand conveyor(ID No. 1-F-SSC). Additionally,the facility requests to inactivate the wood receiving,non-
pneumatic handling and conveying,and storage operations(ID No. IES-SD),the screened clay conveying
and handling operation for kiln I and 2(ID No. IS-3),the brick dryer associated with Kiln I (ID No. I-ES-
KID1),and the brick dryer associated with Kiln 2(ID No. 1-ES-KM).
The following table shows the changes to the insignificant/exempt equipment list for this application. Items
StMek thFOUgh were removed and items italicized are inactive.
Emission Source ID Emission Source Description Exemption Source of Source of Title V
Regulation TAPs. Pollutants.
IES-K4F.1, IES-K4F.2, Box feeder,conveying system,and 2Q.0102(h)(5) No Yes
and IES-K4F.3 storage tank for line 4
IES-CP Open clay storage piles 2 .0102(h)(5) No Yes
IS-4 Screened clay conveying and handling
operation for kiln 3 and 4 2Q .0102(h)(5) No Yes
IES-RECLAIM Reclaimer building storage piles 2 .0102(h)(5) No Yes
IES-F-CO-C I through Coating operations including five
IES-F-CO-05 and IES- conveyors and reclaimer 2Q .0102 (h)(5) No Yes
F-CO-2
IS-7.1 through IS-7.8 Six sand coating piles and two 2Q.0102(h)(5) No Yes
conveyers
IES-F-CH6 Existing raw material handling and
conveying o erations 2Q .0102(h)(5) No Yes
IS-8.1 through IS-8.9 Kiln 3 raw material handling
operations consisting of a storage pile, 2Q .0102 (h)(5) No Yes
box feeder, six conveyors,and a
storage bin
I-F-CH-H and I-F-CH- One hopper(50 ton capacity)and one 2Q 0102(h)(5) No Yes
AF apron feeder
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Emission Source ID Emission Source Description Exemption Source of Source of Title V
Regulation TAPS. Pollutants.
IES-VS1, IES-VS2, Four package-type kiln car vacuuming 2Q 0102(h)(5) No Yes
IES-VS4,and IES-VS5 systems
IES-T1 One 350 gallon brick oil tank 2 .0102(h)(5) Yes No
IES-T2 One 350 gallon gear oil tank 2 .0102(h)(5) Yes No
IES-T3 One 275 gallon waste oil tank 2 .0102(h)(5) Yes No
IES-T4 One 1,000 gallon diesel tank 2 .0102 (h)(5) Yes No
IES-T5 One 1,000 gallon gasoline tank 2 .0102(h)(5) Yes No
IF-BH-MR-DH and One dump hopper and one conveyor at 2Q 0102(h)(5) No Yes
IF-BH-MR-C the Briic1khaven site
1 C�-'i-Gc-�r e QW-1tt'
1 crz-cvni crux
I-F--SSE . Sand Conveyor
IES-VS3 Hi-Vac vacuums stem for Kiln 3 1 2 .0102(h)(5) No Yes
INACTIVE SOURCES
IES-SD(INACTIVE) Wood receiving, non pneumatic
handling and conveying, and storage 2Q.0102 (h)(5) No Yes
operations
IS-3(INACTIVE) Screened clay conveying and handling 2Q 0102(h)(S) No Yes
o eration or kiln I and 2
1-ES-KIDI INACTIVE One brick diyer associated with Kiln 1 2 .0102(h)(5) No Yes
/-ES-K2Dl INACTIVE One brick dryer associated with Kiln 2 2 .0102 h S No Yes
Emissions Review:
The insignificant inactive source emissions were included with the permitted inactive source emissions
calculated above.
Regulatory Review:
The insignificant sources did not have any regulatory changes.
4. NSPS,NESHAPS,PSD,and Attainment Status:
• NSPS:
o Subpart 000,Nonmetallic Mineral Processing, is applicable to the clay handling equipment
(primary crusher(ID No. F-PC),two scalping screens(ID Nos. F-SS1 and F-SS2),secondary
crusher(ID No. F-SGS),two single deck screens(ID Nos. F-FS1 and F-FS2),two finishing
screens(ID Nos. F-FS3 and F-FS4),two finishing conveyors#4 and#5(ID Nos. F-FC4 and F-
FC5),and intersite conveyor(ID No. F-C-CFBH)).
• NESHAPS:None.
• PSD and 1 12(r)are not applicable to this facility.
• Chatham County is in attainment.
5. Facility Wide Air Toxics:
Toxic review was not triggered for this review because no new processes or new equipment were added to
the permit.
6. Compliance Status:
The facility appeared to be in compliance during the most recent inspection conducted by Jeff Harris on
January 14,2021.
7. Facility Emissions Review:
The following permit potential emissions were provided by the facility and were checked and appear to be
correct. Particulate emissions of the active sources exceed the 100 tpy threshold when uncontrolled. If the
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inactive sources are re-activated,the potential emissions could exceed 10 tpy individually and 25 tpy total
for HAPs. This facility is correctly defined as a Synthetic Minor for fee purposes.
Pollutant Permit Potential
tpy
PM 84.91
PM-10 64.54
PM-2.5 64.18
NOx 80.76
CO 87.85
SO2 5.03
VOC 9.72
HF 0.01
HCI 4.73
8. Summary of Permit Changes:
• Permit expiration date updated to June 30,2029.
• Permit classification changed from Title V to Synthetic Minor.
• Updated 15A NCAC 2D .0524,Nonmetallic Mineral Processing Equipment,to reflect the updated
permitted equipment list.
• Updated 15A NCAC 2D .1 100,Control of Toxic Air Pollutants,to include modeling dates and
correct the limestone feeder setting of the DI-As(ID Nos. CD-K3DLA and CD-K4DLA).
• Added 15A NCAC 2D.0605,Compliance Certification. Within 45 days of the issuance date of
permit 04384R40,the Permittee shall submit a compliance certification for calendar year 2021 to
the DAQ and to the EPA.
• Added 15A NCAC 2Q .0315, Limitation to Avoid 15A NCAC 2Q .0501,which includes
operational restrictions and recordkeeping and reporting requirements.
• Removed 15A NCAC 2D .1 109,Case-by-Case MACT for Brick Manufacturers,which is no
longer applicable to the facility as it is no longer a major source for hazardous air pollutants.
• Updated the permitted equipment list and insignificant 1 exempt activities list to reflect inactive
sources.
• Removed the alternate operating scenarios for coal from the description of the two natural
gaslpropane-fired brick tunnel kilns(ID No. ES-K3K and ES-K4K).
• Removed all sources under the headers coal processing system,grinding and screening operations,
block plant,and sand silo system from the permitted equipment list.
• Removed the coal pile(ID No. 1-F-Coal-CP),coal hopper(ID No. I-F-Coal-CH)and sand
conveyor(ID No. 1-F-SSC)from the insignificant 1 exempt activities list.
• Updated control device descriptions for ID Nos. CD-CDBBF,CD-SD-DC I,CD-SD-DC2,CD-SD-
BV 1,and CD-SD-BV2 to remove air-to-cloth ratios and include filter area.
9. Conclusions,Comments,and Recommendations:
Permit 04384R40 should be issued showing the above changes.
Permit Coordinator: Date:
Dena Pittman, P.E.
c�
Regional Supervisor: Date: 7/29/2021
Taylor Hartsfield, EIT,CPM
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