AQ_F_0400043_20210615_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: 07/01/2021 County/FIPS: Anson/007
Facility Data Permit Data
Triangle Brick Company-Wadesboro Brick Manufacturing Plant Permit 08179/T11
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 [phone] Manufacturing
[phone] [phone]
Compliance Data
Comments:
Inspection Date 06/15/2021
Inspector's Name Evangelyn Lowery-Jacobs
Inspector's Signature: A- Operating Status Operating
04 Compliance Status Compliance-inspection
Action Code FCE
Date of Signature: tj J 0Z,r Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
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
2017 38.36 28.42 11.89 5.76 53.90 35.57 1127.59
*Highest HAP Emitted(in pounds)
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
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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 15 June 2021,I,Evangelyn Lowery-Jacobs, of DAQ FRO,met with Mr.Paul Gibson,the Plant
Manager,and Mr. Tommy Meggs,Kiln Supervisor to conduct the annual compliance inspection.-
Triangle is currently operating Kiln(K-1)at approx. 16 tons/hr. Kiln(K-2)has not operated since April
2020;however, it is scheduled to return to service during early July 2021. The facility is hiring additional
employees to operate Kiln K-2,which will be producing a larger brick than is currently fired.
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).
Facility records appeared complete and in accordance with the current requirements outlined in their air
quality permit No. 008179T11. Mr. Meggs and Mr.Gibson escorted me on a tour of the facility. Mr.
Meggs directed me to the DLA where he discussed its operation. Mr. Gibson described the 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 stated that they

Triangle Brick Company-Wadesboro Brick Manufacturing Plant
Compliance Inspection Report
Page 3 of 12
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.
Kiln K-1 was 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:
-
F. _' :3-�"'�' ._--. '�.;�' �' ,4 ,t.�. .r... '_ ,i. -.� ,t+.....''�. _ _ .rk'Y5• �,:� , �lda1-srv. 1.:,. -:=a::
ram - > �.
.- a� �
�: t � :
..:,.,. ��,x... ::. ,t.,,:. •t' .>. .Y', s ..
a: n
«. awv x
One natural gas/No.2 fuel oil/No. 6 fuel oil-fired Dry Limestone
Brick Tunnel Kiln(29.0 tons per hour material output CD-K1 Adsorber(DLA)
K-1 rate,42.8 million Btu per hour heat input rate)
Operating,0`%VE
Operating at—16 TPH
One natural gas/No.2 fuel oil/No. 6 fuel oil-fired Dry Limestone
Brick Tunnel Kiln(29.0 tons per hour material output CD-K2 Adsorber(DLA)
K-2 rate, 42.8 million Btu per hour heat input rate)
Not Operating
Not Operating
77777
SD-1 One natural gas-fired Rotary Coatings Dryer(8.1 tons
of clay per our material input rate, 0.3 million Btu N/A N/A
NSPS UUU per hour heat input rate)
'?:
��:��t�;��.',>��'��?� ���.,. �., . �... ,_. ... � r�ti z ,, ,, .,"�� ;w��.: .,,.� ,� H.... , �,:, _•fir.
PC-1 and Two shale feeders N/A N/A
PC-2
PC-3 and
PC-4 Two scalp screens N/A N/A
NSPS 000
PC-5 and
PC-6 Two jaw crushers N/A N/A
NSPS 000
N/A N/A
PC-7 One conveyor under PC-3 and PC-5

Triangle Brick Company-Wadesboro Brick Manufacturing Plant
Compliance Inspection Report
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.�L.r.,> +.-�+,i..� z ..a >. ..:�fis` E:N� d � c-� ;:-�E v�i' ��r;i „i..��i•�+:3�:i•'a"".:.
.3' tee_ -a•>: � �,•�i-.i-'�`" .,.�: i'�>w.+� a.�. •n�.�•+.t" �.+. rs `� :��.:'�.� t'�:e�.�.. �h �_v:>v:...av_
..•, ..a�+'�.. � �.--,. ���. �� "?C![_ ��,z;. ��:: <r� :.�Vie,
:��'' nos;a��. sk. �.:. �,:. \�:a- -������ a.;, e•�>� �t .apt �. �....,sK:
.c q±�: ,,:•'.1 ,m'°-' Z,..� a "i .�- .�,.. .ia„�.-k. ��......> - �.M`,'�;�• s `M'" tee: �+�y �x'u.
�` '�r'r,,K� 'sitz�„-.. '�.� ass:-�` ,�iR. •�z-� k, � -S 2';.« �,!.. .2=.:.
y..t
.k t zc-me, '.µ
.,.....�.. �ab�.. .�ySrwW.,�s.,av<y����3v��3`�'�.�r.a,.��o-•+rsus,.v.:.r.,s,..���.,.>,.�..->....... :....3��.�-ss>;.t?,�,t. ..�.. <� ., i.:«vr�'� as,�>.- �...:"�✓�3.'�.�..� .�.-::.., �w ..>;.1"�+���._-s.
NSPS 000
PC-8
One conveyor under PC-4 and PC-6 N/A N/A
NSPS 000
PC-9
One cross-over conveyor N/A N/A
NSPS 000
PC-10
One shuttle conveyor N/A N/A
NSPS 000
1 -✓. \T'�\:� \^ S i �.. '�:'. .,Nr+.:: L ���,i;. S "xv. .. fir ..:'+
.. � ��
CG-1 One clay feeder N/A N/A
CG-2
One conveyor belt to scalping screen N/A N/A
NSPS 000
CG-3
NSPS 000 One scalping screen N/A N/A
CG-4
One return conveyor belt for oversize from screens N/A N/A
NSPS 000
CG-5
One conveyor belt to hammer mill N/A N/A
NSPS 000
CG-6
One hammer mill N/A N/A
NSPS 000
CG-7
One conveyor belt under hammer mill N/A N/A
NSPS 000
CG-8
One conveyor belt to finish screens N/A N/A
NSPS 000,
CG-10
through
CG-13 Four finish screens N/A N/A
NSPS 000
CG-14
One fines conveyor belt under screens N/A N/A
NSPS 000
CG-15 N/A
One conveyor belt to storage bins N/A

Triangle Brick Company-Wadesboro Brick Manufacturing Plant
Compliance Inspection Report
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.
NSPS 000
CG-16
One conveyor belt over storage bins N/A N/A
NSPS 000
CG-17
. through
hroug 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
CG-29 One clay feeder �N/A N/A
CG-30
One conveyor belt to scalping screen N/A N/A
NSPS 000
CG-31
One scalping screen N/A N/A
NSPS 000
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
CG-34
One hammer mill N/A N/A
NSPS 000
CG-35
One conveyor belt under hammer mill N/A N/A
NSPS 000
CG-36
One conveyor belt to finish screens N/A N/A
NSPS 000

Triangle Brick Company Wadesboro,Brick Manufacturing Plant
Compliance Inspection Report
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M
1910
S iln,
IN
s.
0
Imwl
CG-37
through
CG-40 Four finish screens N/A N/A
NSPS 000
CG-41
One fines conveyor belt under screens N/A N/A
NSPS-000
CG-42
One conveyor belt to storage bins N/A N/A
NSPS 000
CG-43
NSPS 000 One conveyor belt over storage bins N/A N/A
CG-44
through
CG-48 Five storage bins N/A N/A
NSPS 000
CG-49
through Five feeders under storage bins N/A N/A
CG-53
NSPS 000
CG-54
One conveyor in front of storage bins N/A N/A
NSPS 000
CG-55
One conveyor to pug mill N/A N/A
NSPS 000
LS-1 Loam/sawdust feeder N/A N/A
LS-2 One conveyor.from loam/sawdust feeder N/A N/A
NSPS 000 to finish screens
LS-3
One loam screen N/A N/A
NSPS 000
LS-4
One loam crusher N/A N/A
NSPS 000

Triangle Brick Company-Wadesboro Brick Manufacturing Plant
Compliance Inspection Report
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.�-'��`�-v.'._. ��.`'�-':"„3 m"�e. ram'= ����g`�..'-- ;so:. — w�� �-:�- .s��� '^sw:�:. �-._.-�.�". ��-.—.:d•. 3`�` �:,.}-!
zs.;� - � �' � ��•'.,. a- ���� .�i-,s�'.-.a� �S>`.�..,�.a:�^. aa`�'.s. .as. ..�i;.. �:;:�'-.Y—......":a >-.�.. ..,...... ;'30��.�.4 .s.�,. :-���-�.a... �a-.aaq ..-ram.. �.:..a... ,.
LS-5
One oversize return conveyor from LS-3 N/A N/A
NSPS 000
LS-6
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
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-11
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)
�'' *>:.'.>n x a� a, w��*a>3- :�3.y tea-. t 3 a-az:.� �'�.a "�.�, +-.r�,-�,-�.,x, ,� s. � � � �`�",� � .�- •��&" -�� �'��a
S' ��>- ��� ��� ``fix cS� r",� ��,> �r.-���.n.�T ♦'� ..�'." �"�'±�:'aF�>- �"` z���'^ s..,:.a'a-m �a :ate a `� �..-Y�o �. ;>a- a
�n.2..::.:�....�...........,...., ..�,s`�....�a��._.....-�e�..�.�?.a�.u..;.k _...,.c �,:3 x a.s:, ._a.....zs.....;.�_... c;3,�.._.__`_�..�.�`�� �,�...:: �>...a.;��_,._.ate°..-,..�>.__-�,�.�u a��� '.a�z __?�...a �-,-::v�>..�..�..,•„
IS-Tank 3,000 gallon above ground gasoline storage tank
GACT CCCCCC
IT-1 One 24,000 gallon above ground No. 6 fuel oil storage tank
__ _ _
IT-2 and IT-3 Two 24,000 gallon above ground No.2 fuel oil storage tanks
IT-4 One 24,000 gallon above ground highway diesel fuel oil storage tank
IT-5 One 24,000 gallon above ground Additive"A"storage tank

Triangle Brick Company-Wadesboro Brick Manufacturing Plant
Compliance Inspection Report
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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 '). 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 on 0111812021. K 2 has not operated since
April 2020. The most recent semiannual report was received on 0112812021 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. Kiln K-2 has not
operated since April 2020. Since January 2010, the facility has only used#2 fuel oil as back up
fuel during NG curtailment. The last shipment of No. 6 fuel oil received at the facility(S= 1.3616)
was in 2011 and none of it has been combusted to date. The facility did burn approx..12,600 gals
of#2 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.IMMBtu. 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 was 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. Meggs indicated the kilns are operated primarily
on natural gas; therefore, normal operations result in no visible emissions. The most recent
semiannual report was received on 0112812021 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

Triangle Brick Company-Wadesboro Brick Manufacturing Plant
Compliance Inspection Report
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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.
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
0212312021. The records appeared complete and valid. The most recent semi-annual report was
received on 0112812021 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 0112812021 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
0112812021 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

Triangle Brick Company-Wadesboro Brick Manufacturing Plant
Compliance Inspection Report
Page 10 of 12
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)
visible emissions were observed from the building openings. The most recent semiannual report
was received on 0112812021 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-1 at approximately 16
TPH, and K-2 has not operated since April 2020. The highest hourly rate in the last 12 months was
approximately 16.5 tons for K 1. This process rate is below the permit limits requiring less than 29
TPH and indicates compliance. The most recent semiannual report was received on 0112812021
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 RAPS. Monitoring,Recordkeeping and reporting requirement are
established in permit to demonstrate facility remains minor source for RAPS. These requirements
are summarized below as followed:
Monitoring and Recordkeeping Requirements.
(1) The Permittee shall operate the DLAs(CD-K 1 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

Triangle Brick Company-Wadesboro Brick Manufacturing Plant
Compliance Inspection Report
Page 11 of 12
emissions to less than 10/25 TPYHAPS. The facility records were observed and indicate the DLAs
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.
Mr. Meggs indicated 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
0112812021 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 IN COMPLIANCE— 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 16.5 tons for K-1. K-2 has not operated since April 2020. The most recent report
was received on 0112812021 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 0112812021 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 30'of each
year.
APPEARED IN COMPLIANCE—The facility's 2019 AQEI was received on 0613012020 and
appeared to be complete and accurate. The 2020 AQEI was received on 0612212021 and is
currently under review.
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.
VIH. NON-COMPLIANCE HISTORY SINCE 2010:
05/11/2017 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 06/15/2021.
XI. PINK SHEET ADDITIONS:
None.
/elj