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HomeMy WebLinkAboutAQ_F_0400043_20220607_CMPL_InspRpt NORTH CAROLINA DIVISION OF Fayetteville Regional Office AIR QUALITY Triangle Brick Company-Wadesboro Brick Manufacturing Plant Inspection Report NC Facility ID 0400043 Date: 06/16/2022 County/FIPS: Anson/007 Facility Data Permit Data Triangle Brick Company- Wadesboro Brick Manufacturing Plant Permit 08179/Tl 1 US Hwy 52 Issued 7/13/2018 Wadesboro,NC 28170 Expires 6/30/2023 Lat: 35d 1.1463m Long: 80d 5.1235m Class/Status Title V SIC: 3251 /Brick And Structural Clay Tile Permit Status Active NAICS: 327121 /Brick and Structural Clay Tile Manufacturing Current Permit Application(s)None Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact SIP/Title V David Gibson Howard Brown,Jr. David Gibson NSPS: Subpart 000, Subpart UUU Director of President& CEO Director of Manufacturing (919)226-5623 Manufacturing (704)695-1420 (704)695-1420 Compliance Data Comments: Inspection Date 06/07/2022 Inspector's Name Evangelyn Lowery-Jacobs Inspector's Signature: _ Operating Status Operating Compliance Status Compliance- inspection Action Code FCE Date of Signature: o-�'� �' �Z-t. ' Inspection Result Compliance Total Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PM10 x HAP 2020 39.18 28.62 12.02 5.99 55.05 36.33 1152.30 2019 41.61 30.40 12.77 6.15 58.47 38.59 1223.79 2018 41.43 30.26 12.71 6.19 58.20 38.42 1218.31 Highest HAP Emitted inpounds) Five Year Violation History: None Date Letter Type Rule Violated Violation Resolution Date Performed Stack Tests since last FCE: None Date Test Results Test Method(s) Source(s)Tested Triangle Brick Company-Wadesboro Brick Manufacturing Plant Compliance Inspection Report Page 2 of 12 I. DIRECTIONS TO SITE: From FRO, follow traffic circle to second left on Gillespie Street for 0.3 miles. Turn right on Russell Street for 0.5 miles. Turn left on Robeson Street for 2.4 miles. Turn left on Raeford Road,US-401 South for 20.4 miles through Wagram. South of Wagram, NC, turn right onto Old Wire Road (NC-144) for 12.3 miles to US-74 West. Follow US-74 West for 39.7 miles through Wadesboro and turn right onto US-52 North. Travel approximately 3 miles and turn right into the first facility entrance; the office is located on the left. Check opacities prior to entering(kiln stacks, openings in bldg.with grinders). II. SAFETY: Safety glasses and shoes required; hard hat and ear protection optional. An operating kiln is hot to touch; exiting bricks and cars are hot. Keep hands out of brick-making mechanisms, grinders and extruders. III. FACILITY DESCRIPTION: Triangle Brick Company-Wadesboro is the second largest brick plant in the country. They make a variety of bricks from clay and shale mined onsite. The material they mine is a consistent mixture of clay and shale. As the material is mined, it is trucked up the hill to the facility where it is fed through a sizing grate. The smaller material passes via conveyors to the storage shelter and the oversized material goes through 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(carrying agent is a sawdust/loam mixture),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. IV. INSPECTION SUMMARY: On 7 June 2022,I,Evangelyn Lowery-Jacobs,of DAQ FRO,met with Paul Gibson,Plant Manager, and Edward Dutch,Assistant Plant Manager to conduct the annual compliance inspection. Triangle is currently operating Kiln(K-1)at approx. 20 tons/hr and Kiln(K-2)at approximately 13 tons/hr. Kiln (K-2)returned to service during early July 2021. The facility hired additional employees to operate Kiln K-2,which produces a larger brick. The facility started operating the dry lime adsorber(DLA)on K-2 in August 2016 in advance of their compliance date(September 4, 2016)for the case-by-case MACT for brick manufacturing. They started Kiln#1 on 6 February 2017 with the associated DLA. The facility operates the DLAs on the kilns in order to obtain a Title III(Hazardous Air Pollutants) synthetic minor(area source)classification,thus avoiding the recently promulgated NESHAP 5J(Brick MALT). Mr. Gibson reviewed the FacFinder information and indicated no changes were necessary. I reviewed the facility records to ensure compliance with the current requirements outlined in their air quality permit No. 008179TI 1. Mr. Gibson provided the VE observation records for NSPS 000 via email on 06/08/2022. All records appeared to be complete and current. Mr.Dutch and Mr. Gibson escorted me on a tour of the facility. Mr. Gibson directed me to the DLA where he discussed its operation. Mr. Gibson described the Triangle Brick Company-Wadesboro Brick Manufacturing Plant Compliance Inspection Report Page 3 of 12 limestone low level indicator near the base of the limestone hopper and indicated an alarm is set to activate(visual and audible)when/if the hopper level gets below the low-level indicator. Mr. Gibson confirmed that they routinely refill the hopper every 4-6 weeks,well before the level reaches the low- level indicator. A screw is installed on the DLAs to feed the limestone from the cascades(area where the limestone is reacted with the exhaust stream)to the peeling drum where the outer layer of limestone is "peeled off." The peeling(dust) is dropped to a collection container and the unreacted limestone is blown back up to the hopper to pass through the cascades again. The feeder settings activate the peeling drum on 30 min, off 30 min; screw is on 2 min, off 2 min while the peeling drum is operating. Both kilns were operating during the inspection. During the facility tour,I observed no visible emissions from any of the operating emission sources. V. PERMITTED EMISSION SOURCES: The following table contains a summary of all permitted emission sources and associated air pollution control devices and appurtenances: Emission Control Control Device Source ID Emission Source Description Device Description No. ID No. Two Brick Tunnel Kilns One natural gas/No. 2 fuel oil/No. 6 fuel oil-fired Brick Tunnel Kiln(29.0 tons per hour material output Dry Limestone K-1 CD-K 1 � Adsorber(DLA) rate, 42.8 million Btu per hour heat input rate) Operating at—20 TPH Operating,0%VE One natural gas/No.2 fuel oil/No. 6 fuel oil-fired Brick Tunnel Kiln(29.0 tons per hour material output Dry Limestone I{_2 CD-K2 Adsorber(DLA) rate,42.8 million Btu per hour heat input rate) 1 Operating at 13 TPH Operating,0%VE Rotary Coatings Dryer � SD-1 One natural gas-fired Rotary Coatings Dryer(8.1 tons [i of clay per hour material input rate, 0.3 million Btu N/A N/A ` 1 a NSPS UUU per hour heat input rate) Primary Crushing Plant and Associated Conveyances PC-1 and Two shale feeders N/A N/A PC-2 i PC-3 and PC-4 I Two scalp screens N/A N/A NSPS 000 PC-5 and Two jaw crushers N/A N/A PC-6 Triangle Brick Company-Wadesboro Brick Manufacturing Plant Compliance Inspection Report Page 4 of 12 Emission Control Control Device Source ID Emission Source Description Device No. ID No. Description £.................._.__....._..-...._._..,...... _-__._.._......,..-.._...._.....-.. ._.__. ._.........................._.. -....._...._........,..._,.........._.«.v___.....__.,..,......... NSPS 000 r ___ p PC-/ One conveyor under PC-3 and PC-5 N/A N/A NSPS 000 y One conveyor under PC-4 and PC-6 N/A I N/A NSPS 000 r One cross-over conveyor E N/A N/A NSPS 000 PC-10 j .......... � � One shuttle conveyor N/A N/A NSPS 000 y Two Secondary Clay Grinding Plants and Associated Conveyances CG-1 One clay feeder I�- N/A N/A I CG-2 [ NSPS 000 One conveyor belt to scalping screen N/A # N/A E � I CG-3 NSPS 000 One scalping screen N/A E N/A CG-4 NSPS 000 One return conveyor belt for oversize from screens N/A N/A CG-5 NSPS 000 One conveyor belt to hammer mill N/A N/A NSPS 000 One hammer mill N/A N/A One conveyor belt under hammer mill N/A N/A NSPS 000 !j E � ! CG-8 NSPS 000 One conveyor belt to finish screens N/A N/A I I CG-10 through CG-13 Four finish screens N/A N/A NSPS 000 Triangle Brick Company-Wadesboro Brick Manufacturing Plant Compliance Inspection Report Page 5 of 12 Emission Control Source ID Emission Source Description Device Control Device .._ :�...... R -.� Description t: No. �9 ID No. �CG-14 One fines conveyor belt under screens N/A N/A NSPS 000 I F-C 6-15 One conveyor belt to storage bins N/A N/A NSPS 000 CG-16 One conveyor belt over storage bins N/A N/A NSPS 000 CG-17 ---__� through CG-21 Five storage bins N/A N/A NSPS 000 - CG-22 through CG-26 Five feeders under storage bins N/A N/A NSPS 000 CG-27 One conveyor in front of storage bins N/A N/A NSPS 000 CG-28 One conveyor to pug mill N/A N/A NSPS 000 F- CG-29 One clay feeder N/A N/A CG-30 NSPS 000 One conveyor belt to scalping screen N/A N/A CG-31 NSPS 000 One scalping screen N/A N/A _ CG-32 One return conveyor belt for oversize from screens N/A N/A NSPS 000 CG-33 One conveyor belt to hammer mill N/A N/A NSPS 000 E CG-34 One hammer mill N/A N/A NSPS 000 CG-35 NSPS 000 One conveyor belt under hammer mill N/A N/A � Triangle Brick Company-Wadesboro Brick Manufacturing Plant Compliance Inspection Report Page 6 of 12 Emission Control Source ID Emission Source Description Device Control Device Description No. ID No. CG-36 One conveyor belt to finish screens ' N/A N/A { NSPS 000 CG-37 i through CG-40 Four finish screens N/A N/A NSPS 000 E CG-41 One fines conveyor belt under screens N/A N/A NSPS 000 I � CG-42 One conveyor belt to storage bins N/A N/A NSPS 000 3 _ One conveyor belt over storage bins N/A N/A Y g NSPS 000 through CG-48 Five storage bins N/A N/A NSPS 000 t �CG-49 through CG-53 Five feeders under storage bins N/A N/A E NSPS 000 E CG-54 j One conveyor in front of storage bins N/A N/A NSPS 000 One conveyor to pug mill N/A N/A NSPS 000 Loam/Sawdust Preparation Operation and Associated Conveyances LS-1 Loam/sawdust feeder N/A N/A f � LS-2 One conveyor from loam/sawdust feeder N/A N/A NSPS 000 to finish screens � LS-3 i NSPS 000 One loam screen N/A N/A � i I LS-4 � One loam crusher N/A N/A Triangle Brick Company-Wadesboro Brick Manufacturing Plant Compliance Inspection Report Page 7 of 12 Emission Control Source ID Emission Source Description Device Control Device ID No Description No. �`s.� Ak' I NSPS 000 LS-5 One oversize return conveyor from LS-3 N/A 1 N/A NSPS 000 I F One oversize return chute N/A N/A NSPS 000 LS-7^ One fines conveyor belt under LS-3 to N/A N/A NSPS 000 bunker belt conveyor LS-8 f One belt conveyor to bunker N/A N/A NSPS 000 LS-9 ° One storage bunker N/A N/A NSPS 000 LS-10 One sawdust screen N/A N/A NSPS 000 LS-1 1 One conveyor to storage bins ; N/A N/A NSPS 000 LS-12 ' NSPS 000 One oversize conveyor from sawdust screen N/A N/A VI. INSIGNIFICANT ACTIVITIES per 15A NCAC 02Q .0503(8) ....Emission Source #; Emission Source Description ID No. ��..IS-Tank GACT C 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 241000 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 Triangle Brick Company-Wadesboro Brick Manufacturing Plant Compliance Inspection Report Page 8 of 12 VII. APPLICABLE AIR QUALITY REGULATIONS: A. 15A NCAC 2D .0515 PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES—Particulate emissions from each kiln,K-1 and K-2, shall not exceed 39.14 lbs./hour at a production rate of 29 tons/hour(4.1 x P 0.61). The Permittee shall perform a semi- annual visual inspection of kiln emissions ductwork and a semi-annual visual inspection of the kiln's fuel combustion system and send semiannual summary reports to DAQ. APPEARED IN COMPLIANCE—Facility operates on NG with No. 2 fuel oil as backup. The PM emission rate determined from the 311412006 source test conducted was 2.03 lb./hr for Kiln K 1. The facility was operating at 23.47 TPH with DLA control. The calculated PM emission limit at this operating rate is 34.0 lb./hr. The PM emission rate determined from the 911312016 source test conducted was 3.78 lb./hr for Kiln K-2. The facility was operating at 25.17 TPH with DLA control. The calculated PM emission limit at this operating rate is 35.6 lb./hr. This demonstrated emission rate is for filterable PM only, but since it is so low it is unlikely the Total PM emission rate would exceed the limit. During the inspection, I reviewed I&Mrecords documenting internal and external inspections that were conducted semi-annually for K-1 and K-2 on 1213112021. The most recent semiannual report was received on 0112 712 022 and appeared complete and valid. B. 15A NCAC 2D .0516 SULFUR DIOXIDE CONTROL REQUIREMENT—Sulfur dioxide emissions from each kiln,K-1 and K-2, and from rotary coatings dryer SD-1 shall not exceed 2.3 lbs./MMBtu heat input. For kilns K-1 and K-2,the Permittee shall monitor the sulfur content and the Btu content of the No. 6 fuel oil through fuel supplier certifications,no monitoring requirements when using NG or No. 2 fuel oil. Keep quarterly log of fuel certs when using No. 6 fuel oil. APPEARED IN COMPLIANCE—Kilns K 1 and K 2 normally operate on NG. Since January 2010, the facility has only used No. 2 fuel oil as back up fuel during NG curtailment. The last shipment of No. 6 fuel oil received at the facility (S= 1.3691o) was in 2011 and none of it has been combusted to date. The facility did burn approx. 12,600 gals of 42 fuel oil in Nov 2016 and Jan 2017 due to curtailment. The rotary coatings dryer SD-1 started operation in June 2005 and is designed to operate solely on natural gas. The AP-42 S02 emission factors for NG is 0.0006 lb./MMBtu and for No.2 fuel oil is 0.023 lb./MMBtu. The AP-42 emission factor for S02, when firing No. 6 fuel oil with a maximum sulfur content of 2.1 wt.%, is 2.20 lb/mmBtu. This plant operates primary on NG; therefore, S02 emissions are less than the limitation contained in this permit. C. 15A NCAC 2D .0521 VISIBLE EMISSIONS CONTROL REQUIREMENT—Visible emissions from kilns K-1 and K-2 shall not be more the 20 percent opacity. The Permittee shall observe the kiln emission points once each month for normal vs abnormal and submit semiannual summary reports to DAQ. APPEARED IN COMPLIANCE—During the inspection, K 1 and K 2 were operating with 0% VE from the DLA stacks. The facility continues to log weekly VE observations (surpassing the monthly requirement), and all have been "normal." Mr. Gibson confirmed the kilns are operated primarily on natural gas; therefore, normal operations result in no visible emissions. The most recent semiannual report was received on 0112712022 and appeared complete and valid. D. 15A NCAC 2D .0524 NEW SOURCE PERFORMANCE STANDARDS SUBPART UUU— For the Rotary coatings dryer(SD-1): VE shall not be greater than 10%,the Permittee shall observe the source daily for any VE;the Permittee shall inspect and maintain the rotary coatings dryer in accordance with the manufacturer's recommendation and shall perform a semi-annual internal inspection for deterioration, damage and leaks; and submit semi-annual summary reports to DAQ. Triangle Brick Company-Wadesboro Brick Manufacturing Plant Compliance Inspection Report Page 9 of 12 APPEARED IN COMPLIANCE—The unit was not operating during the inspection. I reviewed the logbook of daily VE observations; all were recorded as "normal,"which was defined by the facility as "No Visible Emissions." The time of each observation is now being recorded as advised by a previous inspector. The last semi-annual inspection on the dryer was conducted on 1213012021. The records appeared complete and valid. The most recent semi-annual report was received on 0112 712 022 and appeared complete and valid. E. 15A NCAC 2D .0524 NEW SOURCE PERFORMANCE STANDARDS SUBPART 000— For the primary crushing plant scalp screens,jaw crushers,and conveyors(ID Nos. PC-3 through PC-10),the Permittee shall comply with the notification and recordkeeping requirements: dates of construction, anticipated startup and actual startup;performance test data; and excess emissions reports. The VE shall not be greater than 10%,except for crushers not greater than 15%; Permittee shall observe the individual sources monthly for normal vs abnormal VE. Permittee shall submit semiannual summary reports to DAQ. APPEARED IN COMPLIANCE—Sources PC-4, 6, 8& 9, have not been installed; therefore, NSPS notifications have not been submitted. All notifications have been submitted for sources PC-3, 5, 7, & 10. Monthly observation records appeared complete, indicating "normal,"where normal is defined by the facility as <10%opacity. These sources are grouped in the logbook, but VE observations are made at the individual sources. The most recent semiannual report was received on 0112712022 and appeared complete and valid. F. 15A NCAC 2D .0524 NEW SOURCE PERFORMANCE STANDARDS SUBPART 000— 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 VE shall not be greater than 10%,except for crushers not greater than 15%. Permittee shall monthly observe building openings for any VE or source stacks for normal vs abnormal VE. Permittee shall submit semiannual summary reports to DAQ. APPEARED IN COMPLIANCE—The facility has chosen to observe the building openings monthly for any VE There are two openings to each half of the grinding building(the building has a dividing wall down the center and two separate clay grinding operations reside in the same building). One conveyor in the grinding operation is in a separate building(milling bldg.)from the rest of the subject sources which require VE observations. Observations are made at both openings monthly for each side of the grinding/mill buildings. The monthly observation records all indicated "normal,"which is then defined by the facility as "No Visible Emissions." Most of the sources in the two buildings were not operating during the inspection, and zero (0) visible emissions were observed from the building openings. The most recent semiannual report was received on 0112712022 and appeared complete and valid. G. 15A NCAC 2D .0524 NEW SOURCE PERFORMANCE STANDARDS SUBPART 000- For the loam/sawdust preparation area, loam screen, loam crusher, storage bunker,sawdust screen, and conveyors(ID Nos. LS-2 through LS-12),non-stack VE shall not be greater than 10% except for crushers not greater than 15%; Permittee shall observe building openings monthly for any VE. Permittee shall submit semiannual reports to DAQ. APPEARED IN COMPLIANCE—There are two openings to each half of the grinding building. Observations are made at both openings,for each side of the grinding building, monthly. The monthly observation records all indicated "normal, "which is then defined by the facility as "No Visible Emissions." The sawdust operations were not operating during the inspection and zero (0) Triangle Brick Company-Wadesboro Brick Manufacturing Plant Compliance Inspection Report Page 10 of 12 visible emissions were observed from the building openings. The most recent semiannual report was received on 0112712022 and appeared complete and valid. H. 15A NCAC 2D .1100 TOXIC AIR POLLUTION EMISSION LIMITATIONS AND REPORTING REQUIREMENT—According to the air toxic compliance demonstration, 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 lbs./hour(29 TPH). Quarterly summary reporting to DAQ. APPEARED IN COMPLIANCE—The facility is currently operating Kiln K I at approximately 20 TPH, and K-2 is operating at approximately 13 TPH. Kiln (K 2) returned to service during early July 2021. The highest hourly rate in the last 12 months was approximately 27.9 tons for K-1 and 13.1 for K 2. This process rate is below the permit limits requiring less than 29 TPH and indicates compliance. The most recent semiannual report was received on 0113112022 and appeared complete and valid. I. 15A NCAC 2D .1806 CONTROL AND PROHIBITION OF ODOROUS EMISSIONS—The Permittee shall prevent odorous emissions from the facility from causing or contributing to objectionable odors beyond the facility's boundary. APPEARED IN COMPLIANCE No odor, associated with this facility, was noticed when entering or exiting the property. DAQ has not received any complaints since the previous inspection. Mr. Gibson stated that the facility has not received any odor complaints and odorous material are not part of the brick manufacturing process. J. 15A NCAC 2Q .0317 AVOIDANCE for MACT—In order to remain classified minor source for HAPS and avoid MACT requirements, facility emissions of HAPS shall be less than 10 TPY of each HAP and 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 below as followed: Monitoring and Recordkeeping Requirements. (1) The Permittee shall operate the DLAs(CD-K1 and K2)when Kilns(K-1 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. (2) The DLAs shall maintain an adequate amount of limestone. (3) The same grade of limestone used during the performance testing shall be used. (4) The Permittee shall maintain the limestone feeder rate settings at or above the settings established during the performance test. Monitor and record each day. (5) The Permittee shall monitor the bypass damper position and record when Kilns are operated when damper is open. (6) Permittee shall record the production rate on a fired product basis for each Kiln and keep records. APPEARED IN COMPLIANCE—Based on prior source test for each Kiln, the HF and HCL emissions have been measured less than 10125 TPY. This measurement was made with the DLAs operating to reduce the HAP emissions. The control of RAPS by the DLAs reduce the actual emissions to less than 10125 TPYHAPS. The facility records were observed and indicate the DLAs Triangle Brick Company-Wadesboro Brick Manufacturing Plant Compliance Inspection Report Page 11 of 12 are in use while Kilns are operating. The records indicate that the limestone is tested to demonstrate quality. Mr. Gibson provided the limestone delivery certification forms for review and confirmed the facility receives automatic deliveries of limestone approximately every three weeks. The limestone levels are monitored daily to ensure the amount and feed rate of limestone is adequate. The bypass vent is observed each day and records indicate it is hard locked to prevent kiln operation when damper is open. The facility has submitted a semi-annual report which summarizes all requirements of this rule. The most recent report was received on 0112712022 and indicated compliance. K. 15A NCAC 2Q.0711 PERMIT REQUIREMENTS FOR TOXIC AIR POLLUTANTS—The Permittee shall operate the facility in such a way that any listed TAP emissions from the facility do not exceed TPERs. APPEARED IN COMPLIANCE—Based on the current and previous 12 months'operating rates, and sources of raw material, Triangle Brick TAP emissions appear to be below the listed TPERs. L. 15A NCAC 2Q .0317 AVOIDANCE CONDITION FOR 15A NCAC 2D .0530 PREVENTION OF SIGNIFICANT DETERIORATION—The sulfur dioxide emissions from each kiln shall be less than 250 tons per 12-month period. K-1 and K-2 production throughput is limited to 58,000 lbs./hour each and the amount of No. 6 fuel oil,with 2.1% sulfur,burned is limited to 920,000 gallons per 12-month period. 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. APPEARED INCOMPLIANCE— The facility burns NG with ultra-low sulfur No. 2 fuel oil as backup only during NG curtailment. The facility was curtailed in Nov 2017 and Jan 2018 and burned approx. 12,600 gals of fuel oil. The facility has not burned any fuel oil; therefore, S02 emissions are not expected to exceed 250 TPY. The highest hourly rate in the last 12 months was approximately 27.9 tons for K 1 and 13.1 for K-2. Kiln (K 2) returned to service during early July 2021. The most recent report was received on 0112712022 and indicated compliance. M. PERMIT GENERAL CONDITION I.A and I.B—REPORTING REQUIREMENTS FOR EXCESS EMISSIONS AND PERMIT DEVIATIONS: 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. APPEARED IN COMPLIANCE—Mr. Gibson stated that the facility has had no excess emission/malfunction events and therefore no notification has been required. N. PERMIT GENERAL CONDITION P- COMPLIANCE CERTIFICATION REQUIREMENT: The facility is required to submit 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. APPEARED IN COMPLIANCE— The latest ACC report was received on 0112712022 and appeared complete and valid. Triangle Brick Company-Wadesboro Brick Manufacturing Plant Compliance Inspection Report Page 12 of 12 O. GENERAL CONDITION X—ANNUAL EMISSION INVENTORY REQUIREMENTS—The permittee shall submit an Annual Emission Inventory postmarked on or before June 30th of each year. APPEARED IN COMPLIANCE—The facility's 2020 AQEI was received on 0613 01202 0 and appeared to be complete and accurate. The 2021 AQEI was received on 0612212022 and appeared complete and valid. The 2021 AQEI was submitted by the facility into AERO on 0611412022. P. PERMIT GENERAL CONDITION MM—FUGITIVE DUST CONTROL REQUIREMENT: The Permittee shall not cause of allow fugitive dust emissions to cause or contribute to substantive complaints or excess visible emissions beyond the property boundary. APPEARED IN COMPLIANCE—Mr. Gibson stated that no dust complaints had been received by the facility, and FRO has not received any dust complaints. There did not appear to be any issues with fugitive dust from our observations on site. The parking lot and general area around the process is paved and no dust was observed. VIII. NON-COMPLIANCE HISTORY SINCE 2010: 05/1 1/2017 NOD issued for late quarterly report submittal; report received 05/12/2017. IX. 112r STATUS: The facility does not store any of the listed chemicals in amounts that exceed the threshold quantities. Therefore,they are not required to maintain a written Risk Management Plan(RMP). X. CONCLUSIONS AND RECOMMENDATIONS: Triangle Brick Co-Wadesboro appeared to be operating IN COMPLIANCE with the requirements outlined in their air quality permit No. 008179T11 during the inspection on 06/07/2022. XI. PINK SHEET ADDITIONS: None. /elj