AQ_F_1900009_20210114_CMPL_InspRpt (4)

NORTH CAROLINA DIVISION OF Raleigh Regional Office WTW
AIR QUALITY General Shale Brick,Inc.-Moncure Facility
NC Facility ID 1900009
Inspection Report County/FIPS: Chatham/037
Date: 01/19/2021
Facility Data Permit Data
General Shale Brick,Inc.-Moncure Facility Permit 04384/T39
300 Brick Plant Road Issued 1/13/2017
Moncure,NC 27559 Expires 12/31/2021
Lat: 35d 34.3530m Long: 79d 2.0830m 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
J.Warren Paschal Kevin Ham J.Warren Paschal MACT Part 63: Subpart Brick-112j
Manager of VP Engineering& Manager of NSPS: Subpart 000
Environmental Research Environmental
Compliance [phone] Compliance
919 774-6533 919 774-6533
Compliance Data
Comments: Compliance inspection—Appears to be in compliance.
Inspection Date 01/14/2021
Inspector's Name Jeff Harris
Inspector's Signature: C Operating Status Operating
Compliance Status Compliance-inspection
Action Code FCE
Date of Signature: 1/19/21 Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2019 60.57 0.75 29.22 4.19 74.32 60.57 3426.7
2018 69.62 0.85 33.3 4.68 84.70 66.33 4458.27
2017 66.78 0.8300 32.39 4.57 82.42 64.42 4349.70
*Highest HAP Emitted inpounds)
Five Year Violation History:None
Date Letter Tyne Rule Violated Violation Resolution Date
Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested
(I)DIRECTIONS: General Shale Brick's Moncure Facility(General Shale)is located off Corinth Road in Moncure, Chatham
County. From Raleigh,take the beltline to US-1 South. Follow US-1 South for 17 miles to the exit for Old US 1 South. Turn
right off the exit ramp onto SR 1011. Travel approximately 4 miles and take a left onto Corinth Road(SR 1923). The facility
is approximately 4 miles down Corinth Road on the right.

(II)FACILITY DESCRIPTION: 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 the brick kilns.
There are four brick kilns at the Moncure facility,two of which are older wood-fired kilns(Kilns 1 and 2) and two of which are
newer kilns(Kilns 3 and 4). Kilns 4 was converted from coal to natural gas in 2015 and Kiln 3 is currently not operational since
all the coal fuel system has been removed. Plans have been drafted to convert Kiln 3 to natural gas as their primary fuel like
Kiln 4,but the conversion is on indefinite hold due to economic considerations. 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.
Note: Kilns 1 and 2 are also referred to as the Cape Fear plant or Plant#24, and Kiln 3 and 4 are referred to as the Brickhaven
plant or Plant#25. The Cape Fear plant has not operated since 2007 and is unlikely to operate again.
Safety Note: Standard personal protective equipment for this facility would include,but not limited to,hard hat, safety glasses,
hearing protection, and safety shoes.
(II1)INSPECTION SUMMARY: On January 14, 2021,I(Jeff Harris)met with Mr.Warren Paschal, Manager of
Environmental Compliance for General Shale, for the purpose of conducting an air quality permit compliance inspection.
Before the on-site inspection,Mr. Paschal provided most necessary records via e-mail. All records were complete and up to
date. Mr. Paschal indicated that as in previous years,the conversion of Kiln 3 from coal to natural gas has not occurred and the
unit remains idle with all coal fuel having been removed from the facility. On my arrival,Mr. Paschal and I toured the facility.
At the time of my inspection,the only brick tunnel kiln operating was Kiln 4 and it appeared to be operating well from an air
quality standpoint with opacity of zero percent from the DLA stack. It was operating on a schedule of 24 cars/day or 16.12
tons/hour. Comments about observations made during the inspection are provided below for each of the emission sources and
specific conditions listed in the facility's current air permit.
(IV) PERMITTED EMISSION SOURCES: At the time of the inspection, General Shale's Moncure Plant was operating
under Air Permit No. 04384T39,which was issued on January 13,2017, expires on December 31,2021, and includes the
following emission sources and control devices:
A. Brick tunnel kilns 11 2, 3, and 4 and associated dryers consisting of:
Two wood/natural gas-fired brick tunnel kilns (27 million Btu per hour maximum heat input rate
and 13.7 tons per hour maximum fired brick production rate, each, ID Nos. ES-KI and ES-K2)
and associated sawdust rotary dryer(ID No. ES-WD1,2);
One coal/natural gas/propane-fired brick tunnel kiln (25.9 million Btu per hour maximum heat
input rate and 20.55 tons per hour maximum fired brick production rate, ID No. ES-K3K) and
associated dry limestone adsorber(ID No. CD-K3DLA) and the three associated natural
gas/propane-fared brick dryers (ID Nos. ES-K3D1, ES-K3D2, and ES-K3D3); and
One coal/natural gas/propane-fared brick tunnel kiln (25.9 million Btu per hour maximum heat
input rate and 20.55 tons per hour maximum fared brick production rate, ID No. ES-K4K) and
associated dry lime injection fabric falter(ID No. CD-K4DIFF) and the three associated natural
gas/propane-fared brick dryers (ID Nos. ES-K4D1, ES-K4D2, and E4-K3D3);
Kiln ES-K4K was the only kiln in operation at the time of my inspection and it was firing natural gas. I did
not observe any visible emissions(VE) from the DLA stack and no VE from the dryer stacks. At the time
of my inspection the kiln was operating on schedule of 24 cars/day or 16.12 tons/hour.

B. One wood fuel/sawdust system consisting of two 8 x 8 screen, cyclone, hammermill, sawdust silo,
surge hopper, transfer screw conveyor, screen feed conveyor, and enclosed conveyor(ID Nos. ES-
WFS-SD-SCI, ES-WFS-SC2, ES-WFS-SD-CYC, ES-WFS-SD-HM, ES-WFS-SD-SDS, ES-WFS-SD-
SH, ES-WFS-SD-CV], ES-WFS-CV2, and ES-WFS-SD-CV3) controlled by two dust collectors, one
cyclone, and two bin vent filters (ID Nos. CD-SD-DC], CD-SD-DC2, ES-WFS-SD-CYC, CD-SD-
BVI, and CD-SD-BV2);
This equipment was not operating at the time of my inspection. The facility no longer uses wood as
fuel.
C. Natural gas-fired coatings rotary dryer(3.45 tons of coatings per hour maximum drying capacity,
250,000 Btu per hour firing rate,ID No. ES-CD-8);
This equipment was not operating at the time of my inspection. The coatings dryer dries the
coating material itself,prior to its application to the uncured bricks, so its operation is intermittent.
D. Two texturizing operations (ID Nos. ES-CR5 and ES-CR6) controlled by two bagfilters (6,096 and
3,040 square feet of filter area, respectively, ID Nos. CD-CR6BF and CD-CR6BF2), one
texturizing operation (ID No. ES-CR7) controlled by two bagfilters (6,096 and 4,062 square feet of
filter area respectively, ID Nos. CD-CR7BF and CD-CR7BF2), and sand silo system (ID No. ES-
SS) controlled by one bin ventfilter(ID No. CD-SS-BV3);
The texturizing equipment associated with Kiln 4 was operating at the time of my inspection.
ES-CR5 & CR6 are associated with Kilns 1 &2 and are no longer operated.
E. Clay crushing, grinding, and screening operations including one NSPS-affected primary crusher
(ID No. F-PC), two NSPS-affected scalping screens (ID Nos. F-SSI and F-SS2), one NSPS-affected
hammermill (ID No. F-HM), two single deck finishing screens (ID Nos. F-FSI and F-FS2), one
bank of seven finishing screens (ID Nos. F-FS3, F-FS4, F-FSS through F-FS9), two NSPS-affected
finishing conveyors #4 and #5 (ID Nos. F-FC4 and F-FCS), and one NSPS-affected intersite
conveyor(ID No. F-C-CFBH);
This equipment was not operating at the time of my inspection.
F. One NSPS-affected grinding and screening operation (184 tons per hour maximum process rate)
consisting of
one impact crushers (ID No. F-CH-CI)
two scalping screens (ID Nos. F-CH-SSI and F-CH-SS2)
two hammermills (ID Nos. F-CH-HI and F-CH-H2)
four finishing screens (ID Nos. F-CH-FSI through F-CH-FS4)
seventeen conveyors (ID Nos. F-CH-FC, F-CH-SSFC, F-CH-PI, F-CH-P2, F-CH-RC, F-CH-BC,
F-CH-CFC, F-CH-TI, F-CH-T2, F-CH-HFC], F-CH-HFC2, F-CH-TC], F-CH-TC2, F-CH-SFC-
1, F-CH-SFC2, F-CH-SFC3, F-CH-SFC4);
This equipment has not yet been installed as reported in previous inspections and that continues to
be the case at the time of this inspection.

G. One Concrete Block Plant consisting of one flyash silo (ID No. ES-BP-FAS) controlled by one bin
vent filter (227 square feet of filter area, ID No. CD-BP-BVI), one cement silo (ID No. ES-BP-CS)
controlled by one bin vent filter (227 square feet of filter area, ID No. ES-BP-BV2) and one batch
mixer (ID No. ES-BP-BM) controlled by one bagfilter (535 square feet of filter area, ID No. CD-
BP-BHI); and
This equipment was not operating at the time of my inspection.
H. One coal processing system one coal crusher(ID No. ES-Coal-CC) controlled by one bagfilter(ID
No. CD-Coal-CC)
This equipment was not operating at the time of my inspection. The facility no longer uses coal as
fuel.
(V) SPECIFIC PERMIT CONDITIONS: As is the case with all Title V permits, Air Quality Permit No. 43 84T3 9 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 all of the permitted emission sources that are subject to a
specific regulation are noted.
(1) 15A NCAC 2D.0515:PARTICULATE FROM MISCELLANEOUS INDUSTRIAL PROCESSES-Permit Items A, B, C, D, G,
and Hare subject to 2D.0515.
Appears 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 the sources. No particulate emission testing is required by the facility's air permit. To
ensure compliance with the particulate emission limit,the facility is required to conduct monthly and annual inspections on all
control devices and semiannual inspections on the brick kilns. The facility is required to keep records of all inspection and
maintenance activities and submit a summary report every six months documenting any compliance exceptions. The inspection
and maintenance records appeared to be adequate. The six-month summary reports for 2019 were submitted on time.
(2) 15A NCAC 2D.0516:SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES-Permit Items A and
C are subject to 2D.0516.
Appears to be in compliance-The sulfur dioxide emission limit for each of these sources is 2.3 pounds per million Btu heat
input. No testing is required by the facility's air permit. No monitoring/record keeping/reporting is required for the combustion
of wood,natural gas, and propane in the combustion equipment. For coal combustion in Kilns 3 and 4,when operating under
the Alternative Operating Scenario(AOS),the sulfur content of all coal burned in the kilns must be less than 1.0 percent by
weight. To ensure compliance with this limit,the facility is required to monitor the sulfur content of all coal received at the
facility,maintain a logbook showing all coal received is below 1 percent by weight sulfur, and submit a summary report every
six months documenting any compliance exceptions. At the time of this inspection, as was the case at last year's inspection,
there is no coal at the facility and they continue to operate using natural gas only.
(3) 15A NCAC 2D. 0521: CONTROL OF VISIBLE EMISSIONS-Permit Items A, B, C, D, E, and H are subject to 2D.0521.
Appears to be in compliance-The visible emission limit for the Kilns 1 and 2 (ID No. ES-K1 and ES-K2),the sawdust dryer
(ID No. WD1,2),the coatings dryer(ID No. ES-CD), and two of the texturing operations (ID Nos. ES-CD5 and ES-CD6)is 40
percent opacity. Kilns 1 and 2 and their associated sources are not operating. The visible emission limit for all other emission
sources is 20 percent opacity. During the inspection,all of the emission sources observed in operation were well below their
respective 2D .0521 visible emissions standard.
No visible emission testing/monitoring/record keeping/reporting is required for any of emission sources other than those that
burn coal or process coal. For coal combustion sources operating under the AOS,the facility is required to monitor the visible
emissions once per week. The facility is required to maintain a logbook documenting all visible emissions observations and

submit a summary report every six months documenting any compliance exceptions. Upon request,plant personnel were able to
provide me with records of visible emission observations. The six-month summary reports for 2019 were submitted on time.
(4) 15A NCAC 2D.0524:NEW SOURCE PERFORMANCE STANDARDS(40 CFR 60, Subpart 000) -Permit Items E and F
are subject to NSPS Subpart 000.
Appears 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. Upon request,plant personnel
were able to provide me with records of monthly visible emission observations. The six-month summary reports for 2019 were
submitted on time.
It should be noted that the facility's permit outlines some additional NSPS notification,testing,monitoring,record keeping, and
reporting for the yet to be installed Kiln 4 grinding and screening operation(Permit Item F). According to Mr. Paschal,the
facility is prepared to meet all NSPS requirements for these emission sources once construction has commenced.
(5) 15A NCAC 2D.1100 and 2Q.0711: TOXIC AIR POLLUTANT REQUIREMENTS -All of the permitted emission sources
are subject to 2D.I100 and 2Q.0711.
Appears 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 2D .1100,the permittee must maintain operational records to
ensure that the operational restrictions outlined in the permit are met. These restrictions are 54,800 pounds of brick per hour for
Kilns 1 and 2 and 82,200 pounds of brick per hour for Kilns 3 and 4. During Q4 of calendar year 2020,the highest production
rate for Kilns 1&2 and Kilns 3&4 was 0.0 pounds of brick per hour and 33,864 pounds of brick per hour,respectively. The
facility is required to submit quarterly reports demonstrating compliance with the operational restrictions.All recent quarterly
reports have been submitted on time and have demonstrated compliance with the toxics operational limits.
To comply with 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.
During the inspection,Mr.Paschal pointed out an error in the current permit in stipulation 2.2 A.2a.vi which states"The
limestone feeder setting of the DLAs (ID Nos. CD-K3DLA and CD-K4DLA) shall be maintained at or above 110 pounds per
hour averaged over a 24-hour block period."Mr.Reece notes that this should say 30 lb/hr,and should be fixed in the next
permit revision. Similar notes for 2.2 A.2a.xi.
(6) 15A NCAC 2D.1109: CAA§1126); Case-by-Case MA CT FOR BRICK MANUFACTURERS—The following equipment is
subject to 2D.1109: The large brick tunnel kilns 3&4 (ID Nos. ES-K3K and K4K) and the smaller brick tunnel kilnsl&2 (ID
Nos. ES-KI and Ks).
APPEARS TO BE IN COMPLIANCE—The initial compliance date for the emissions standards,work practice standards, and
associated monitoring,recordkeeping,and reporting requirements was July 29,2015. The conversion of Kiln 4 from coal to
natural gas was completed in approximately three (3)months and initial performance testing was completed on September 24,
2015. The conversion of Kiln 3 from coal to natural gas will take place later and the kiln remains"out of service". All the coal
that was at the facility has been transported to one of their sister facilities.Logbooks showing records of required parameters
and limestone quality records were provided and appeared adequate.

(7) 15A NCAC 2D.1806: CONTROL AND PROHIBITION OF ODOROUS EMISSIONS—All of the permitted emission sources
are subject to 2D.1806.
Appears 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.
(VI)EXEMPT EMISSION SOURCES: The facility currently has several emission sources listed on the facility's insignificant
activities attachment to the permit. No concerns were noted during the inspection with regard to these sources. Additionally,no
additional exempt emission sources were observed that would need inclusion on the permit's insignificant activities list.
(VII) COMPLIANCE HISTORY: According to the RRO compliance databases,General Shale's Moncure facility has
received no prior Notice of Violations(NOV)in the last five years. On July 26,2006, an NOV/NRE was issued to the facility
for not maintaining the required pressure drop across the dry limestone adsorber(DLA) (ID No. CD-K4DLA. On December 21,
2006, an NOV was issued to the facility for several missed recordings of the daily limestone feeder setting for the same dry
limestone adsorber. On March 7, 2008, a Notice of Continuing Violation was issued to the facility for combusting coal in the
Kiln ES-K4K without using the required dry lime injected fabric filter(CD-K4DIFF). The facility received a civil penalty
assessment of$5473.00 on December 3,2008. On March 25,2009,an NOV was issued for a late semiannual report.
(VIII)EMISSIONS INVENTORY REVIEW: Brick production for 2019 was down 12 percent from the brick production in
2018 and that accounts for the vast majority of percent change for the pollutants emitted in 2019. Reductions in HCl and HF are
higher percentages,but all emissions of these species result from Kiln 4(ES-K4K),which had a 12%lower throughput for
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—General Shale 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 HISTORY: According to the IBEAM database,the most recent stack test performed at this facility was
performed on September 24,2015. Prior to that,a stack test was performed in February of 2006. Both tests involved brick
tunnel kiln 4(ES-K4K0).
(XI) CONCLUSIONS/RECOMMENDATIONS: Based on this inspection, General Shale's Moncure facility appears to be in
compliance with all applicable requirements. It is also recommended that this facility be re-inspected in one year.

General Shale (1900009)
Facility Contacts
Our database currently lists the following contacts, please provide correct names and full contact
information if any are incorrect: Correct
Authorized Contact- Kevin Ham, VP Engineering& Research
Facility Contact-Warren Paschal, Manager of Environmental Compliance
Technical Contact-Warren Paschal, Manager of Environmental Compliance
General/Operations Questions: Please explain any "Yes"answers.
• Is the facility operating on a modified schedule or modified production? Currently operating only Kiln 4
at 16.12 tons/hour production rate.
• Are the facility staff whose tasks are directly related to air compliance monitoring working on a
modified schedule or remote location? Employees onsite
• The facility permit requires periodic visible emissions tests and maintenance of process&control
equipment. Do you anticipate any problems performing these activities? No
• Has the facility experienced any episodes of excess emissions lasting more than 4 hours due to
malfunction, breakdown, etc? No
• Has the facility equipment been modified or reconfigured since the last DAQ inspection in February
2019? No
• Has the facility received any complaints regarding dust or odors? No
Records Request
(Please submit whatever format is easiest, whether a scan or a photo of logbook pages.) For logbooks,
please provide most current page, plus two recent additional representative pages (assuming one
page/month, if annual one page is OK.) If records are maintained electronically, please provide the
equivalent.
1) A copy of your current air permit 04384T39 (The first page showing the date is sufficient.) See
Attachment
2) A summary of any currently permitted equipment which is out of service, and reasons why.
ES-K1 & ES-K2, ES WD1, 2—not operating, inventory not needed
KS-K3, ES-K3D1, ES-K3D2 & ESK3D3 - not operating, inventory not needed
Coal Processing System - ES-Coal-CC—converted to natural gas
Wood Fuel/Sawdust System - ES-WFS—not operating wood fuel kilns
Grinding&Screening Operations (184 tons/hour)—not constructed
Texturizing Operations—ES-CR5 & CR6—not operating Kilns 1 & 2
Block Plant—ES-BP—Plant shut down
Rumbler System—ES-Rumble—not rumbling brick products
3) Which Kilns are currently operational, and what fuels are they using? Kiln 4 Natural Gas
What is their typical throughput in cars/day? Currently 24 cars/day 16.12 tons/hour
Is there any progress on plans to convert Kiln 3 to NG? No

4) 15A NCAC 02D .0515: Particulate Emissions: See Attachment
a) Please provide maintenance & inspection logbooks for the following:
Brick Tunnel Kilns ES-K1 to K4
Sawdust Rotary Dryer ES-WD1, ES-WD 2
wood fuel/sawdust system WFS-SD-SC1&2
Texturizing Bag Filters ES-CR5 through 8
Concrete Block Plant
Coal Processing
5) 15A NCAC 02D .0521 Visible Emissions: See Attachment
a) Please provide Visible Emissions test logbooks for the following:
Brick Tunnel Kilns (AOS Only) ES-K1 & K2
Brick Tunnel Kilns (AOS Only) ES-K3 & K4
Sawdust Rotary Dryer(AOS Only) ES-WD1, ES-WD 2
Brick Dryers (AOS Only) ES-K3D1,2,3,
ES-K4D1,2,3
Dry Lime Adsorbers (M22 Daily/Weekly) K3DLA, K4DLA
Coatings Dryer CD-8
Clay Handling Systems (NSPS 000)
Coal Processing
b) Have the additional grinding/screening processes for Kiln 4 been constructed? (If so, please
provide fugitive VE monitoring records)
6) 15A NCAC 02D .1109: CAA§ 112(j); Case-by-Case MACT for Brick Manufacturers: See Attachment
a) Production log for each Kiln, product fired basis
b) Logbooks showing the following operations:
i) Annual Inspection of tunnel kilns K1K, K2K
ii) Maintenance log for K3K, K4K (showing DLA Bypass for maintenance)
iii) Daily Pressure Drop Log (Dry Lime Adsorbers K3DLA, K4DLA)
iv) Daily lime hopper check log (DLA K3DLA, K4DLA)
v) Limestone quality records log (DLA K3DLA, K4DLA)
vi) Daily Limestone feeder setting log (DLA K3DLA, K4DLA)
vii) Monthly limestone feed rate check (DLA K3DLA, K4DLA)
7) 15A NCAC 02D .1100: CONTROL OF TOXIC AIR POLLUTANTS—See Attachment
a) Records of hourly brick production rates for each kiln