AQ_F_1900077_20211216_CMPL_InspRpt (4)

NORTH CAROLINA DIVISION OF Raleigh Regional Office WTW
AIR QUALITY Triangle Brick Company-Merry Oaks Brick
Manufacturing Plant
Inspection Report NC Facility ID 1900077
Date: 12/17/2021 County/FIPS: Chatham/037
Facility Data Permit Data
Triangle Brick Company-Merry Oaks Brick Manufacturing Plant Permit 06897/T12
294 King Rd Issued 5/14/2018
Moncure,NC 27559 Expires 4/30/2023
Lat: 35d 38.5250m Long: 79d 0.0560m Class/Status Title V
SIC: 3251 /Brick And Structural Clay Tile Permit Status Active
NAILS: 327121 /Brick and Structural Clay Tile Manufacturing Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP/Title V
Buck Reece Howard Brown,Jr. Buck Reece NSPS: Subpart 000, Subpart UUU
Plant Manager President&CEO Plant Manager
[phone] [phone] [phone]
Compliance Data
Comments: Compliance Inspection—Appears to be in compliance
Inspection Date 12/16/2021
Inspector's Name Jeff Harris
Inspector's Signature: C- Operating Status Operating
Compliance Status Compliance-inspection
Action Code FCE
Date of Signature: 12/17/21 Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2020 68.49 4.98 10.12 5.35 45.94 66.12 2499.91
2019 76.06 5.54 11.24 5.70 51.08 73.42 2779.16
2018 68.11 4.94 10.08 6.21 45.61 65.76 2479.91
*Highest HAP Emitted inpounds)
Five Year Violation History:
Date Letter Type Rule Violated Violation Resolution Date
05/12/2017 NOV Avoidance 2D .1109 1120)Case-by-Case Maximum 06/12/2017
Achievable Control Technology
Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested
(I) DIRECTIONS: Triangle Brick Company's Merry Oaks Plant is located off US-1 South in Merry Oaks, Chatham
County,North Carolina. From Raleigh, take US-1 South to exit 84 onto Old US-1 South. Turn right onto Old US 1,
follow approximately 1/4 mile, and take a left onto SR 1912, Christian Chapel Church Road. Cross the train tracks
and turn left onto SR 1911, King Road. The facility is easily visible from King Road&US-1.

(II)FACILITY DESCRIPTION: The Merry Oaks Plant operates three brick kilns (Kiln ID Nos. 1, 2, 3) and
historically has manufactured approximately 4 million bricks per week. Kilns I and 2 were installed in 1991 and
each has a capacity of 24 cars/day. Each brick car serving Kilns 1 and 2 can hold a maximum of 6,408 bricks. Using
a conservative factor of 4.5 pounds/brick, the ton per hour process rate for Kilns I and 2 calculates to 13.8 tons/hour.
The maximum permitted production rate for each kiln is 14.5 tons/hour. Kiln 3 began operation in 1999. According
to staff, the kiln has a capacity for 25 cars/day. The brick cars serving Kiln 3 can hold 18,144 brick each. The ton
per hour process rate for kiln 3 calculates to 27.2 tons per hour. The maximum permitted production rate for Kiln 3 is
29 tons/hour.
Safety Note: Personal protective equipment for this facility should include: hard hat, safety glasses, hearing
protection, and safety shoes.
(III) INSPECTION SUMMARY: On December 16, 2021, I (Jeff Harris) met with Mr. Buck Reece, Director of
Manufacturing for Triangle Brick, for the purpose of conducting an air quality permit compliance inspection. Prior to
the on-site inspection, I e-mailed Mr. Reece requesting relevant records, which he provided quickly. At the time of
this compliance inspection, the facility was operating Kiln 3 at a 16 car per day schedule, and the facility appeared to
be operating well from an air quality standpoint with no visible emissions (VE) from the Kiln 3 stack and no odorous
emissions (OE) from the facility.
The dry lime adsorber on Kiln 3 has experienced some issues during 2021, exacerbated by inability to obtain
replacement parts due to supply chain issues. The cellular wheel sluice inside the rotary air lock had to be removed
because after many years it was worn to the point of needing replacement. This part was ordered in July 2021 and
shipment from Germany was significantly delayed due to global supply chain issues. Without this rotary gate valve,
the chemical stone cannot be scaled and conveyed to the top of the DLA. To remain in Compliance the facility is
discarding whole limestone pellets instead of scaled powder/dust. The ultimate result is greater amounts of limestone
being discarded, and significant excess cost for limestone. By doing this, the facility has been able to maintain
required limestone levels. As of the day of the inspection, Mr. Reece had received notification that the replacement
part had finally arrived in the US from Germany and should be delivered soon.
Details regarding each of the emission sources and specific air quality regulations listed in the facility's current air
permit are included below.
(IV) PERMITTED EMISSION SOURCES: At the time of the inspection, Triangle Brick Company was operating
under Air Quality Permit No. 06897T12, which became effective on May 14, 2018, expires on April 30, 2023, and
includes the following emission sources and control devices:
(a)Primary Crushing and Associated Conveyance including: Shale Feeder (ID No. PC-]) and NSPS affected
facilities consisting of a scalp screen (ID No. PC-2),jaw crusher(ID No. PC-3), and three conveyors (ID Nos. PC-4,
PC-S, and PC-6);
This equipment was not operating at the time of the inspection. This equipment provides the raw material for all three
kilns. The raw material used comes from a nearby site owned by Triangle Brick. The equipment appeared to be in
sound condition.

(b) Clay Grinding Operations (Feeders (ID Nos. CG-I and CG-29) and NSPS affected facilities consisting of
conveyors, screens, and hammer mills (ID Nos. CG-2 thru CG-20, CG-22 thru CG-28, and CG-30 thru CG-49);
This equipment was not operating at the time of the inspection but had been earlier in the day. This equipment helps
prepare the raw material for all three kilns. The equipment appeared to be in sound condition.
(c)Brick Tunnel Kilns (ID Nos. K-1, K-2, and K-3; 14.5, 14.5, and 29 tons per hour fared-brick capacity,
respectively) with associated dry lime cascade adsorber units;
Kiln K-3 was observed in operation and was on a sixteen (16) car per day schedule at the time of my visit. Kiln K-1
and Kiln K-2 were not operating and have not run since approximately 2008.
(d)Natural Gas Fired Rotary Coatings Dryer(ID Nos. SD-1).
This equipment was not in operation at the time of the inspection. The coatings dryer dries the coating material itself,
prior to its application to the uncured bricks, so its operation is intermittent.
(V)APPLICABLE AIR QUALITY REGULATIONS: As is the case with all Title V permits, Air Quality Permit
No. 06897T12 lists all of the air quality regulations that apply to each of the permitted emission sources. To avoid
redundancy in this report, the applicable air quality regulations are discussed individually, and the permitted emission
sources that are subject to a specific regulation are noted.
(1) 15A NCAC 2D.0515: PARTICULATE FROM MISCELLANEOUS INDUSTRIAL PROCESSES— The following
emission sources are subject to 2D .0515: The shale feeder(ID No. PC-]), clay feeders (ID Nos. CG-I and CG-29),
and brick kilns (ID Nos. K-1, K-2, and K-3).
APPEARED TO BE IN COMPLIANCE—The particulate emission limit for each of the subject emission sources is
determined based on the individual process weight rates for each source. According to previous permit reviews, all
these sources should meet the applicable 15A NCAC 2D .0515 emission limit under normal operating conditions. No
monitoring, recordkeeping, or reporting is required for the particulate matter emissions from these sources.
(2) 15A NCAC 2D.0516: SULFUR DIOXIDE EMISSIONS FROM COMB USTION SOURCES— The following
emission sources are subject to 2D .0516: The three brick kilns (ID Nos. K-1, K-2, &K-3) and the rotary coatings
dryer (ID Nos. SD-1).
APPEARED TO BE IN COMPLIANCE—The sulfur dioxide emission limit for each of the subject emission sources
is 2.3 pound per million Btu heat input. There is no testing, monitoring, record keeping, or reporting requirements for
sulfur dioxide emissions from the firing of natural gas and No. 2 fuel oil. To demonstrate compliance with the sulfur
dioxide limitation when firing No. 6 fuel oil, the facility is required to monitor all fuel oil shipments to the plant site
to ensure that the sulfur content does not exceed 2.1 percent by weight. Records of fuel oil certifications must be kept
on site. The facility is also required to submit a semiannual summary report and clearly document any deviations to
the monitoring and record keeping requirements. Based on a review of facility records and RRO files, the facility
appeared to be complying with the requirements of 15A NCAC 2D .0516. The facility utilized natural gas exclusively
during 2021, and no new deliveries of fuel oil of any type were received. Accordingly, the S02 emission levels of
natural gas would be far below the limits.

(3) 15A NCAC 2D.0521: CONTROL OF VISIBLE EMISSIONS— The following emission sources are subject to 2D
.0521: The shale feeder (ID No. PC-]), the clay feeders (ID Nos. CG-1 and CG-29), and the three brick kilns (ID
Nos.K-1, K-2, &K-3).
APPEARED TO BE IN COMPLIANCE—The visible emission limit for each of the subject emission sources is 20
percent opacity when averaged over a six-minute period. No visible emissions were noted from any of the permitted
emission sources during the inspection. No visible emission testing is required by the facility's air permit. The permit
requires the facility to perform monthly visible emissions observations, record the results of the VE evaluations in a
logbook, and submit a summary report of the daily observations on a semiannual basis. According to the logbooks of
visible emissions observations that I reviewed for this equipment, monthly observations are being performed by Mr.
Reece and none of the observations indicated anything but "normal". The facility has established"normal" as no
visible emissions.
(4) 15A NCAC 2D.0524: NEW SOURCE PERFORMANCE STANDARDS(40 CFR 60 SUBPART 000 -
STANDARDS OF PERFORMANCE FOR NONMETALLIC MINERAL PROCESSING PLANTS) — The following
emission sources are subject to 2D .0524, Subpart 000: Scalp screen (ID No. PC-2),jaw crusher (ID No. PC-3),
conveyor under PC-2 &PC-3 (ID No. PC-4), cross- over conveyor (ID No. PC-5), shuttle conveyor (ID No. PC-6),
hammer mills (ID Nos. CG-6& CG-34), screens, conveyor belts, &feeders (ID Nos. CG-2 thru CG-20;ID Nos. CG-
22 thru CG-28;ID Nos. CG-30 thru CG-49; respectively).
APPEARED TO BE IN COMPLIANCE—To comply with the requirements of Subpart 000, the facility must
maintain particulate and visible emissions below the source specific limits defined in the permit. The permit requires
the facility to conduct monthly visible observations on all NSPS-affected equipment. The facility must also record the
results of the monthly observations in a logbook and submit a summary report of all visible emission observations on
a semiannual basis. Based on a review of facility records, the facility appeared to be complying with the requirements
of 15A NCAC 2D .0524, Subpart 000.
(5) 15A NCAC 2D.0524: NEW SOURCE PERFORMANCE STANDARDS(40 CFR 60 SUBPART UUU-
STANDARDS OF PERFORMANCE FOR CALCINERS AND DRYERS IN MINERAL IND USTRIES) — The following
emission source is subject to 2D.0524, Subpart UUU: The rotary coatings dryer(ID Nos. SD-1).
APPEARED TO BE IN COMPLIANCE—To comply with the requirements of Subpart UUU, the facility must
maintain particulate and visible emissions below the source specific limits defined in the permit. The rotary coatings
dryer started operation on July 5, 2006. The permit requires the facility to conduct a performance test within 180 days
of initial startup. This test was completed on February 2, 2007, and the results demonstrated compliance with the
applicable standards. The permit also requires the facility to conduct monthly visible observations and perform
periodic inspections and maintenance as needed and as recommended by the manufacturer(at a minimum a
semiannual internal inspection) of the rotary sand dryer. The facility must also record the results of the monthly
observations and the results of inspection and maintenance in a logbook and submit a summary report of all visible
emission observations and the periodic inspections and maintenance on a semiannual basis. Based on a review of
facility records and RRO files, the facility appeared to be complying with the requirements of 15A NCAC 2D .0524,
Subpart UUU.
(6) 15A NCAC 2D.I 100 and 2Q.0711: TOXIC AIR POLL UTANT REQUIREMENTS— The following emission
sources are subject to 2D .1100 and 2Q.0711: The three brick kilns (ID Nos. K-1, K-2, and K-3).
APPEARED TO BE IN COMPLIANCE - In conjunction with a prior permit application, the permittee submitted air
modeling results that demonstrated that emissions of the Toxic Air Pollutants (TAPs) listed in the permit were below

state Ambient Air Standards (AALs)beyond the fence line of the facility. To comply with 15A NCAC 2D .1100, the
permittee must maintain actual emissions of these TAPS below the emission limits outlined in the permit.
To comply with 15A NCAC 2Q .0711, the Permittee must ensure that emissions of specified TAPs do not exceed the
Toxic (Permit Emission Rates (TPERs) specified in the permit. If any of the TPERs are exceeded, the facility must
obtain a permit to emit TAPs and demonstrate compliance with state AALs. According to the facility's 2020 annual
emissions inventory, all actual toxic pollutant emissions are well below the applicable emission limits.
7) 15A NCAC 2D .1806: CONTROL AND PROHIBITION OF ODOROUS EMISSIONS(STATE ONLY
REQUIREMENT)— The following emission sources are subject to 2D.1806: All facility-wide affected emission
sources.
APPEARED TO BE IN COMPLIANCE—To comply with 2D .1806, the Permittee shall not operate the facility
without implementing management practices or installing and operating odor control equipment sufficient to prevent
odorous emissions from the facility from causing or contributing to objectionable odors beyond the facility's
boundary. No objectionable odors were detected during the compliance inspection. No odorous emissions
testing/monitoring/record keeping/reporting is required by the facility's air permit.
(8) 15A NCAC 2Q.0317: PREVENTION OF SIGNIFICANT DETERIORATION(PSD)AVOIDANCE CONDITIONS
— The following emission sources are subject to the 2D .0530 avoidance condition: The three brick kilns (ID Nos.K-1,
K-2, &K-3).
APPEARED TO BE IN COMPLIANCE—To avoid applicability of 15A NCAC 2D .0530, sulfur dioxide (S02)
emissions from the facility must not exceed 250 tons per consecutive 12-month period each. The permit requires the
facility to monitor the amount of natural gas and fuel oil combusted in the three kilns, keep monthly records of fuel
combustion and S02 calculations, and submit quarterly reports demonstrating compliance with the S02 emission
limit. Representative samples of required logs were provided. All recent quarterly reports from this facility have been
submitted on time and have demonstrated compliance with the PSD avoidance limit.
(9) 15A NCAC 2Q.0317: MAHMUMACHEIVABLE CONTROL TECHNOLOGY(MACT)AVOIDANCE
CONDITIONS— The following emission sources are subject to the 2D.II I I avoidance condition: The three brick
kilns (ID Nos.K-1. K-2. &K-3).
APPEARED TO BE IN COMPLIANCE—To avoid the applicability of 15A NCAC 2D .I I I I and remain classified a
minor source for hazardous air pollutants (HAPs), facility-wide emissions of any individual HAP must be less than
10 tons per year and all HAPs combined must be less than 25 tons per year. The facility reported in their first semi-
annual report for 2021 that the greatest individual HAP was hydrogen fluoride with a rolling total 12-mo emission for
the first half of 2021 of 6,570 pounds. This permit condition became effective on January 23, 2018 with the issuance
of revision T11. Compliance is expected.
Additionally, representative copies of records required for maintenance and multiple process parameters were
provided.
(VI) EXEMPT EMISSION SOURCES: The facility currently has several emission sources listed on the
Insignificant Activities List attached to the current air permit. No additional emission sources were observed during
the inspection that would need to be added to the Insignificant Activities List, and no concerns were noted with
regard to the operation or permit exemption status of the current sources on the list.

(VII) COMPLIANCE HISTORY: The facility was issued a Notice of Deficiency (NOD) on May 31, 2017 for late
quarterly reporting. On May 12, 2017, a Notice of Violation(NOV) was issued for a failed stack test of Kiln 3 which
was originally tested on September 12, 2016. On April 3, 2008, the facility was issued a Notice of Violation/Notice
of Recommendation for Enforcement(NOV/NRE) and was fined $2,190 for the associated report violation. On June
6, 2007, a Notice of Violation(NOV) was issued regarding incomplete reporting for the 2nd half of 2006. Prior to that
an NOV was issued on March 30, 2004 for incomplete reporting in your 2003 annual compliance certification. Prior
to that an NOV was issued on December 15, 2003 for failure to submit a semiannual report for the first half of 2003
by the July 30, 2003 due date.
(VIII) EMISSIONS INVENTORY REVIEW: Kiln 3 was the only kiln that operated in 2020 and most changes
resulted from an increase in overall production of approximately 12 percent over 2019.
(IX) CLEAN AIR ACT SECTION 112(r)REQUIREMENTS: Pursuant to 15A NCAC 2D .2100 "Risk
Management Program," if the Permittee is required to develop and register a risk management plan pursuant to
Section 112(r) of the Federal Clean Air Act, then the Permittee is required to register this plan with the USEPA in
accordance with 40 CFR Part 68.
RMP Not Required—Triangle Brick Merry Oaks is subject to the 112(r)program general duty clause, but does not
maintain regulated chemicals onsite above the threshold quantities, which would require a risk management plan.
(X) STACK TEST REVIEW: The most recent stack test at this facility was a"retest"performed on February 9,
2017, on Kiln 3 to demonstrate compliance with 2D .1109 Case by Case MACT. Prior to that, on September 12,
2016, the initial performance test for Kiln 3 to show compliance with 2D .1109 Case by Case MACT was conducted
but the test results indicated an exceedance of the particulate limit and thus the need to retest.
(XI) CONCLUSIONS/RECOMMENDATIONS: At the time of this inspection, Triangle Brick Company-Merry
Oaks appeared to be in compliance with the terms and conditions of air quality permit number 06897T12. It is
recommended that this facility be inspected again in a year.