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Home My WebLink AboutAQ_F_1900009_20210729_PRMT_Permit STATE ROY COOPER �� Governor ELIZABETH S.BISER i Secretary ecy alnn+N�,w . MICHAEL A.ABRACZINSKAS NORTH CAROLINA Director Environmental Quality July 29, 2021 Mr. Kevin Ham VP Engineering & Research General Shale Brick, Inc. - Moncure Facility 3015 Bristol Highway Johnson City, TN 37601 Subject: Air Permit No. 04384R40 General Shale Brick, Inc. - Moncure Facility Moncure, Chatham County,North Carolina Permit Class: Synthetic Minor Facility ID# 1900009 Dear Mr. Ham: In accordance with your completed application received July 28, 2021, we are forwarding herewith Permit No. 04384R40 to General Shale Brick, Inc. - Moncure Facility, Moncure, Chatham County,North Carolina for the construction and operation of air emissions sources or air cleaning devices and appurtenances. Additionally, any emissions activities determined from your air permit application as meeting the exemption requirements contained in 15A NCAC 2Q .0102 have been listed for information purposes as an "ATTACHMENT" to the enclosed air permit. Please note the records retention requirements are contained in General Condition 2 of the General Conditions and Limitations. If any parts, requirements, or limitations contained in this permit are unacceptable to you, you have the right to request a formal adjudicatory hearing within 30 days following receipt of this permit, identifying the specific issues to be contested. Such a request will stay the effectiveness of the entire permit. This hearing request must be in the form of a written petition, conforming to G.S. 150B-23 of the North Carolina General Statutes, and filed with the Office of Administrative Hearings, 6714 Mail Service Center, Raleigh,NC 27699-6714. The form for requesting a formal adjudicatory hearing may be obtained upon request from the Office of Administrative Hearings. Unless a request for a hearing is made pursuant to G.S. 15013-23, this air permit shall be final and binding. You may request modification of your air permit through informal means pursuant to G.S. 15013-22. This request must be submitted in writing to the Director and must identify the specific provisions or issues for which the modification is sought. Please note that the permit will become final and binding regardless of a request for informal modification unless a request for a hearing is also made under G.S. 15013-23. �{( North Carolina Department of Environmental Quality I Division of Air Quality /)Raleigh Regional Office 13800 Barrett Drive I Raleigh,NC 27609 NORTH CAROLINA Department Of Environmental Quality 919.791.4200 T I 919.881.2261 F General Shale Brick, Inc. - Moncure Facility July 29, 2021 Page 2 Unless exempted by a condition of this permit or the regulations, construction of new air pollution sources or air cleaning devices, or modifications to the sources or air cleaning devices described in this permit must be covered under a permit issued by the Division of Air Quality prior to construction. Failure to do so is a violation of G.S. 143-215.108 and may subject the Permittee to civil or criminal penalties as described in G.S. 143-215.114A and 143- 215.114B. This permit shall be effective from July 29, 2021 until June 30, 2029, is nontransferable to future owners and operators, and shall be subject to the conditions and limitations as specified therein. Changes have been made to the permit stipulations. The Permittee is responsible for carefully reading the entire permit and evaluating the requirements of each permit stipulation. The Permittee shall comply with all terms, conditions, requirements, limitations and restrictions set forth in this permit. Noncompliance with any permit condition is grounds for enforcement action, for permit termination, revocation and reissuance, or modification, or for denial of a permit renewal application. Specific changes and additions are summarized below (note: this list may not include all changes and additions): • Permit expiration date updated to June 30, 2029. • Permit classification changed from Title V to Synthetic Minor. • Updated 15A NCAC 2D .0524,Nonmetallic Mineral Processing Equipment, to reflect the updated permitted equipment list. • Updated 15A NCAC 2D .1100, Control of Toxic Air Pollutants, to include modeling dates and correct the limestone feeder setting of the DLAs (ID Nos. CD-K3DLA and CD- K41)LA). • Added 15A NCAC 213 .0605, Compliance Certification. Within 45 days of the issuance date of permit 04384R40, the Permittee shall submit a compliance certification for calendar year 2021 to the DAQ and EPA. • Added 15A NCAC 2Q .0315, Limitation to Avoid 15A NCAC 2Q .0501, which includes operational restrictions and recordkeeping and reporting requirements. • Removed 15A NCAC 2D .1109, Case-by-Case MACT for Brick Manufacturers, which is no longer applicable to the facility as it is no longer a major source for hazardous air pollutants. • Updated the permitted equipment list and insignificant/exempt activities list to reflect inactive sources. • Removed the alternate operating scenarios for coal from the description of the two natural gas/propane-fired brick tunnel kilns (ID No. ES-K3K and ES-K4K). • Removed all sources under the headers coal processing system, grinding and screening operations, block plant, and sand silo system from the permitted equipment list. • Removed the coal pile (ID No. I-F-Coal-CP), coal hopper(ID No. I-F-Coal-CH) and sand conveyor(ID No. I-F-SSC) from the insignificant/exempt activities list. • Updated control device descriptions for ID Nos. CD-CD8BF, CD-SD-DC I, CD-SD-DC2, CD-SD-BV1, and CD-SD-BV2 to remove air-to-cloth ratios and include filter area. General Shale Brick, Inc. - Moncure Facility July 29, 2021 Page 3 Should you have any questions concerning this matter, please contact Sindy Huang at 919-791- 4276. Sincerely, Taylor Hartsfield, EIT, CPM, Regional Supervisor Division of Air Quality,NC DEQ SH Enclosures c: Raleigh Regional Office General Shale Brick, Inc. - Moncure Facility July 29, 2021 Page 4 Page intentionally left blank. NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION DEPARTMENT OF ENVIRONMENTAL QUALITY DIVISION OF AIR QUALITY AIR PERMIT NO. 04384R40 Issue Date: July 29, 2021 Effective Date: July 29, 2021 Expiration Date: June 30, 2029 Replaces Permit: 04384T39 To construct and operate air emission source(s) and/or air cleaning device(s), and for the discharge of the associated air contaminants into the atmosphere in accordance with the provisions of Article 21B of Chapter 143, General Statutes of North Carolina(NCGS) as amended, and other applicable Laws, Rules and Regulations, General Shale Brick, Inc. -Moncure Facility 300 Brick Plant Road Moncure, Chatham County,North Carolina Permit Class: Synthetic Minor Facility ID# 1900009 (the Permittee) is hereby authorized to construct and operate the air emissions sources and/or air cleaning devices and appurtenances described below: Emission Emission Source Control Control System Source ID Description System ID Description ACTIVE EMISSION SOURCES Brick Processing Line 3-Brickhaven Plant#25 ES-K3D1, Three natural gas/propane-fired brick ES-K3D2, dryers(4.43 million Btu per hour heat N/A N/A ES-K3D3 input,each) ES-K3K Natural gas/propane-fired brick tunnel kiln(25.9 million Btu per hour heat CD-K3DLA Dry limestone adsorber input and 20.55 tons per hour maximum fired brick production rate) Brick Processing Line 4-Brickhaven Plant#25 ES-K4D1, Three natural gas/propane-fired brick ES-K4D2, dryers(4.43 million Btu per hour heat N/A N/A ES-K4D3 input,each) ES-K4K Natural gas/propane-fired brick tunnel kiln(25.9 million Btu per hour heat CD-K4DLA Dry limestone adsorber input and 20.55 tons per hour maximum fired brick production rate) Coatings Dryer ES-CD-8 Natural gas-fired rotary drum coatings dryer(250,000 Btu per hour heat input; CD-CD8BF One bagff t square o 3.45 tons per hour drying capacity) feet of filter er area) Permit No. 04384R40 Page 2 Emission Emission Source Control Control System Source ID Description System ID Description Clay Handling Equipment(200 tons per hour maximum capacity) F-SS1 (NSPS), Two scalping screens N/A N/A F-SS2(NSPS) F-FS1 (NSPS), Two single deck screens N/A N/A F-FS2(NSPS) F-FS3 (NSPS), Seven finishing screens F-FS4(NSPS), N/A N/A F-FS5,F-FS6,F-FS7, F-FS8,F-FS9 F-FC4(NSPS), Two finishing conveyors#4 and#5 N/A N/A F-FC5 (NSPS) F-PC(NSPS) Primary crusher N/A I N/A F-SGS(NSPS) I Secondary crusher N/A N/A F-C-CFBH(NSPS) lIntersite conveyor N/A N/A Texturizing Operations ES-CR7 Texturizing operation for line 3 Bagfilter(6,096 square feet CD-CR7BF1, of filter area),bagfilter CD-CR7BF2 (4,062 square feet of filter area) ES-CR8 Texturizing operation for line 4 CD-CR7BF3 bagfilter(3,040 square feet of filter area) Rumbler System ES-RUMBLE Rumbler system One bagfilter(2,292 square CD-RUMBLE feet of filter area) INACTIVE EMISSION SOURCES (Initial start-up and resultant emissions shall be recorded.Refer to Condition A.13) Brick Processing Lines 1 And 2-Cape Fear Plant#24(INACTIVE) ES-Kl (INACTIVE), Two wood/natural gas-fired brick ES-K2(INACTIVE) tunnel kilns(20.3 million Btu per hour N/A N/A heat input and 13.7 tons per hour fired brick production rate,each) ES-WD1,2(INACTIVE) One rotary sawdust dryer(5.59 tons per Two simple cyclones hour drying capacity;heated by recycle CD-Cl, heat from kilns 1 and 2 with natural gas CD-C2 operating in parallel(89 inches in diameter each) used as a supplemental fuel) Wood Fuel/Sawdust System(INACTIVE) ES-WFS-SD-CV 1 Transfer screw conveyor and screw (INACTIVE), feed conveyor ES-WFS-SD-CV2 Bagfilter(241 square feet of (INACTIVE) CD-SD-DC 1 filter area) ES-WFS-SD-SC1 8x8 screen (INACTIVE) ES-WFS-SD-SC2 8x8 screen (INACTIVE) Bagfilter(241 square feet of ES-WFS-SD-CYC Cyclone CD-SD-DC2 ) filter area (INACTIVE) ES-WFS-SD-HM Hammermill Cyclone(42 inches in (INACTIVE) CD-WFS-SD- diameter)in series with CYC,CD-SD- bagfilter(241 square feet of DC2 filter area) Permit No. 04384R40 Page 3 Emission Emission Source Control Control System Source ID Description System ID Description EACTI SD-SDS Sawdust silo CD-SD-BV 1 One bin vent filter(90 (INACTIVE) square feet of filter area) ES-WFS-SD-SH Surge hopper One bin vent filter(90 (INACTIVE) CD-SD-BV2 square feet of filter area) ES-WFS-SD-CV3 Enclosed conveyor N/A N/A (INACTIVE) Texturizing Operations(INACTIVE) ES-CR5 (INACTIVE), Two texturizing operations for lines 1 bagfilter(6,096 square feet ES-CR6(INACTIVE) land 2 CD-CR6BF of filter area) in accordance with the completed application 1900009.21B received July 28, 2021 including any plans, specifications,previous applications, and other supporting data, all of which are filed with the Department of Environmental Quality, Division of Air Quality (DAQ) and are incorporated as part of this permit. This permit is subject to the following specified conditions and limitations including any TESTING, REPORTING, OR MONITORING REQUIREMENTS: A. SPECIFIC CONDITIONS AND LIMITATIONS I. Any air emission sources or control devices authorized to construct and operate above must be operated and maintained in accordance with the provisions contained herein. The Permittee shall comply with applicable Environmental Management Commission Regulations, including Title 15A North Carolina Administrative Code (NCAC), Subchapter 2D .0202, 2D .0515, 2D .0516, 2D .0521, 2D .0524 (40 CFR 60, Subpart 000), 2D .0535, 2D .0540, 2D .0605, 2D .1100, 2D .1806, 2Q .0315 and 2Q .0711. 2. PERMIT RENEWAL AND EMISSION INVENTORY REQUIREMENT - The Permittee, at least 90 days prior to the expiration date of this permit, shall request permit renewal by letter in accordance with 15A NCAC 2Q .0304(d) and(f). Pursuant to 15A NCAC 2Q .0203(i), no permit application fee is required for renewal of an existing air permit(without a modification request). The renewal request (with application Form A) should be submitted to the Regional Supervisor, DAQ. Also, at least 90 days prior to the expiration date of this permit, the Permittee shall submit the air pollution emission inventory report (with Certification Sheet) in accordance with 15A NCAC 2D .0202, pursuant to N.C. General Statute 143 215.65. The report shall be submitted to the Regional Supervisor, DAQ and shall document air pollutants emitted for the 2028 calendar year. 3. PARTICULATE CONTROL REQUIREMENT - As required by 15A NCAC 2D .0515 "Particulates from Miscellaneous Industrial Processes," particulate matter emissions from the emission sources shall not exceed allowable emission rates. The allowable emission rates are, as defined in 15A NCAC 2D .0515, a function of the process weight rate and shall be determined by the following equation(s), where P is the process throughput rate in tons per hour(tons/hr) and E is the allowable emission rate in pounds per hour(lbs/hr). E=4.10 * (P) 0.67 for P <=30 tons/hr, or E= 55 * (P) 0-"-40 for P >30 tons/hr Permit No. 04384R40 Page 4 4. SULFUR DIOXIDE CONTROL REQUIREMENT -As required by 15A NCAC 2D .0516 "Sulfur Dioxide Emissions from Combustion Sources," sulfur dioxide emissions from the combustion sources shall not exceed 2.3 pounds per million Btu heat input. 5. VISIBLE EMISSIONS CONTROL REQUIREMENT -As required by 15A NCAC 2D .0521 "Control of Visible Emissions," visible emissions from the emission sources, manufactured after July 1, 1971, shall not be more than 20 percent opacity when averaged over a six-minute period, except that six-minute periods averaging not more than 87 percent opacity may occur not more than once in any hour nor more than four times in any 24-hour period. However, sources which must comply with a visible emissions standard in 15A NCAC 2D .0524 "New Source Performance Standards" or .1110 "National Emission Standards for Hazardous Air Pollutants" shall meet that standard instead of the 2D .0521 visible emissions standard. 6. VISIBLE EMISSIONS CONTROL REQUIREMENT -As required by 15A NCAC 2D .0521 "Control of Visible Emissions," visible emissions from the texturizing operation for Line 1 (ID No. ES-CR5 (INACTIVE)), texturizing operation for Line 2 (ID No. ES-CR6 (INACTIVE)), wood/natural gas-fired tunnel brick kiln(20.3 million Btu per hour heat input and 13.7 tons per hour fired brick production rate) (ID No. ES-K1 (INACTIVE)), wood/natural gas-fired tunnel brick kiln(20.3 million Btu per hour heat input and 13.7 tons per hour fired brick production rate) (ID No. ES-K2 (INACTIVE)), and rotary sawdust dryer (5.59 tons per hour drying capacity; heated by recycle heat from kilns 1 and 2 with natural gas used as a supplemental fuel) (ID No. ES-WD1,2 (INACTIVE))manufactured as of July 1, 1971, shall not be more than 40 percent opacity when averaged over a six-minute period, except that six-minute periods averaging not more than 90 percent opacity may occur not more than once in any hour nor more than four times in any 24-hour period. However, sources which must comply with a visible emissions standard in 15A NCAC 2D .0524 "New Source Performance Standards" or .1110 "National Emission Standards for Hazardous Air Pollutants" shall meet that standard instead of the 2D .0521 visible emissions standard. 7. 15A NCAC 2D .0524 "NEW SOURCE PERFORMANCE STANDARDS" -For the nonmetallic mineral processing equipment(wet material processing operations, as defined in 60.671, are not subject to this Subpart) including Scalping Screen (ID No. F-SS1), Scalping Screen(ID No. F-SS2), Finishing conveyor#4 (ID No. F-FC4), Finishing conveyor#5 (ID No. F-FC5), Finishing screen(ID No. F-FS3), Finishing screen(ID No. F-FS4), Single deck screen (ID No. F-FS1), Single deck screen(ID No. F-FS2), Intersite conveyor(ID No. F-C- CFBH), Primary crusher(ID No. F-PC) and Secondary crusher(ID No. F-SGS), the Permittee shall comply with all applicable provisions, including the notification, testing, reporting, recordkeeping, and monitoring requirements contained in Environmental Management Commission Standard 15A NCAC 2D .0524 "New Source Performance Standards" (NSPS) as promulgated in 40 CFR 60, Subpart 000, including Subpart A "General Provisions." a. NSPS Reporting Requirements -In addition to any other notification requirements to the Environmental Protection Agency(EPA), the Permittee is required to NOTIFY the Regional Supervisor, DAQ, in WRITING, of the following: i. The actual date of initial start-up of an affected facility, postmarked within 15 days after such date; Permit No. 04384R40 Page 5 b. NSPS Emissions Limitations -As required by 15A NCAC 2D .0524 [40 CFR 60.672], the following permit limits shall not be exceeded: i. For affected facilities that commenced construction, modification, or reconstruction after August 31, 1983 but before April 22, 2008 (wet material processing operations, as defined in 60.671, and Like-For-Like-Replacement, as allowed in 60.670(d), are not subject to this Subpart): Affected Facility Pollutant Emission Limit Affected facilities with dry capture systems (i.e., bagfilters) except for a system that controls only PM 0.022 gr/dscf an individual enclosed storage bin Affected facilities with dry capture systems (i.e., Visible 7% opacity bagfilters) Emissions Crushers Visible 15% opacity Emissions Fugitive emissions from conveyor belts, Visible 10% opacity screening operations, and other affected facilities Emissions A. If an affected facility is enclosed in a building, the affected facility must comply with the limits listed above OR the building enclosing the affected facilities must comply with a visible emissions limit of seven(7)percent opacity from the building openings (except for vents as defined in 60.671) and a particulate emission limit of 0.022 grains per dry standard cubic foot from the vents. ii. For affected facilities that commenced construction, modification, or reconstruction on or after April 22, 2008 (wet material processing operations, as defined in 60.671, and Like-For-Like-Replacement, as allowed in 60.670(d), are not subject to this Subpart): Affected Facility Pollutant Emission Limit Affected facilities with dry capture systems (i.e., bagfilters) except for a system that controls only PM 0.014 gr/dscf an individual enclosed storage bin Dry capture system installed only on an Visible 7% opacity individual enclosed storage bin Emissions Crushers Visible 12% opacity Emissions Fugitive emissions from conveyor belts, Visible 17% opacity screening operations, and other affected facilities Emissions Permit No. 04384R40 Page 6 A. If an affected facility is enclosed in a building, the affected facility must comply with the limits listed above OR the building enclosing the affected facilities must comply with a visible emissions limit of seven(7)percent opacity from the building openings (except for vents as defined in 60.671) and a particulate emission limit of 0.014 grains per dry standard cubic foot from the vents. c. Like-For-Like-Replacement-As provided in 40 CFR 60.670(d), when an existing facility is replaced by a piece of equipment of equal or smaller size, as defined in 40 CFR 60.671, having the same function as the existing facility, and there is no increase in the amount of emissions, the new facility is exempt from the provisions of 40 CFR 60.672, 60.674, and 60.675 except as provided for in 60.670(d)(3). The Permittee shall comply with the reporting requirements of 40 CFR 60.676(a). Equipment covered under 40 CFR 60.670 shall comply the requirements of 15A NCAC 2D .0521. 8. NOTIFICATION REQUIREMENT -As required by 15A NCAC 2D .0535, the Permittee of a source of excess emissions that last for more than four hours and that results from a malfunction, a breakdown of process or control equipment or any other abnormal conditions, shall: a. Notify the Director or his designee of any such occurrence by 9:00 a.m. Eastern time of the Division's next business day of becoming aware of the occurrence and describe: i. the name and location of the facility, ii. the nature and cause of the malfunction or breakdown, iii. the time when the malfunction or breakdown is first observed, iv. the expected duration, and V. an estimated rate of emissions. b. Notify the Director or his designee immediately when the corrective measures have been accomplished. This reporting requirement does not allow the operation of the facility in excess of Environmental Management Commission Regulations. 9. FUGITIVE DUST CONTROL REQUIREMENT -As required by 15A NCAC 2D .0540 "Particulates from Fugitive Dust Emission Sources," the Permittee shall not cause or allow fugitive dust emissions to cause or contribute to substantive complaints or excess visible emissions beyond the property boundary. If substantive complaints are received or excessive fugitive dust emissions from the facility are observed beyond the property boundaries for six minutes in any one hour(using Reference Method 22 in 40 CFR, Appendix A), the owner or operator may be required to submit a fugitive dust plan as described in 2D .0540(f). Permit No. 04384R40 Page 7 "Fugitive dust emissions" means particulate matter that does not pass through a process stack or vent and that is generated within plant property boundaries from activities such as: unloading and loading areas,process areas stockpiles, stock pile working,plant parking lots, and plant roads (including access roads and haul roads). 10. COMPLIANCE CERTIFICATION - Pursuant to 15A NCAC 2D .0605: Within 45 days of the issuance date of Permit No. 04384R40, the Permittee shall submit a compliance certification to the DAQ and to the EPA (Air and EPCRA Enforcement Branch, EPA, Region 4, 62 Forsyth Street, Atlanta, GA 30303). The compliance certification shall encompass the current calendar year from January 1 st through the effective date of this permit and be certified by a responsible official with all federally-enforceable terms and conditions in the Title V Permit No. 04384T39, including emissions limitations, standards or work practices as described in the Title V permit in accordance with 15 A NCAC 2Q .0508(m). The compliance certification shall comply with additional requirements as may be specified under Sections 114(a)(3) or 504(b) of the Federal Clean Air Act. The compliance certification shall specify: a. the identification of each term or condition of the Title V permit that is the basis of the certification; b. the compliance status; c. whether compliance was continuous or intermittent; and d. the method(s)used for determining the compliance status of the source, currently and over the reporting period. 11. TOXIC AIR POLLUTANT EMISSIONS LIMITATION AND REPORTING REQUIREMENT - Pursuant to 15A NCAC 2D .1100 "Control of Toxic Air Pollutants," and in accordance with the approved application for an air toxic compliance demonstration, the permit limits in the table below shall not be exceeded. The Permittee has submitted a toxic air pollutant dispersion modeling analysis dated August 13, 2008 for the facility's toxic air pollutant emissions as listed in the below table. The modeling analysis was reviewed and approved by the DAQ Air Quality Analysis Branch (AQAB) on September 10, 2008. Placement of the emission sources, configuration of the emission points, and operation of the sources shall be in accordance with the submitted dispersion modeling analysis and should reflect any changes from the original analysis submittal as outlined in the AQAB review memo. Affected Source(s) Toxic Air Pollutant F Emission Limit Two (2) wood/natural gas-fired Arsenic & Compounds (total mass of tunnel brick kilns (20.3 million elemental AS, arsine and all inorganic F05 pounds per year, com ounds ASC 7778394 bined Btu per hour heat input and 13.7 compounds) ( ( )) tons per hour fired brick Beryllium Metal (unreacted) 0.0744 pounds per year, production rate, each) (ID Nos. (Component of BEC) (7440-41-7) combined Permit No. 04384R40 Page 8 Affected Source(s) Toxic Air Pollutant F Emission Limit ES-K1 (INACTIVE) and ES-K2 Cadmium Metal, elemental, unreacted r528 pounds per year, (INACTIVE)) (Component of CDC) (7440-43-9) mbined Chromium (VI) Soluble Chromate 0.0316 pounds per day Compounds (Component of CRC) (24-hour), combined (SolCR6) Nickel metal (Component of NIC) 0.0222 pounds per day (7440-02-0) 1(24-hour), combined Arsenic & Compounds (total mass of elemental AS, arsine and all inorganic 18.9 pounds per year compounds) (ASC (7778394)) Beryllium Metal (unreacted) 2.18 pounds per year Natural gas/propane-fired brick (Component of BEC) (7440-41-7) tunnel kiln (25.9 million Btu per hour heat input and 20.55 tons per Cadmium Metal elemental unreacted(Component of CDC) (7440-43-9) 2.70 pounds per year hour maximum fired brick production rate) (ES-K3K) Chromium (VI) Soluble Chromate 0.0252 pounds per day Compounds (Component of CRC) (24-hour) 1(SolCR6) Nickel metal (Component of NIC) 0.0356 pounds per day (7440-02-0) 1(24-hour) Arsenic & Compounds (total mass of elemental AS, arsine and all inorganic 18.9 pounds per year compounds) (ASC (7778394)) Beryllium Metal (unreacted) Natural gas/propane-fired brick (Component of BEC) (7440-41-7) 2.18 pounds per year tunnel kiln(25.9 million Btu per Cadmium Metal elemental unreacted hour heat input and 20.55 tons per (Component of CDC) (7440-43-9) F 0 pounds per year hour maximum fired brick production rate) (ES-K4K) Chromium (VI) Soluble Chromate 0.0252 pounds per day Compounds (Component of CRC) (24-hour) (SolCR6) 1Nickel metal (Component of NIC) 0.0356 pounds per day (7440-02-0) 1(24-hour) Two (2) wood/natural gas-fired Benzene (71-43-2) 474 pounds per year, tunnel brick kilns (20.3 million combined Btu per hour heat input and 13.7 0.0534 pounds per hour tons per hour fired brick Chlorine (7782-50-5) 1.28 pounds per day production rate, each) (ID Nos. (24-hour), combined ES-K1 (INACTIVE) and ES-K2 DEHP (Di(2-ethylhexyl)phthalate) 15 pounds per day(24- (INACTIVE)) and 1(117-81-7) our), combined Two (2) natural gas/propane-fired Fluorides (sum of all fluoride 22.0 pounds per hour brick tunnel kilns (25.9 million compounds as mass of F ion) (16984- 528 pounds per day Btu per hour heat input and 20.55 48-8) (24-hour), combined Permit No. 04384R40 Page 9 Affected Source(s) Toxic Air Pollutant F Emission Limit tons per hour maximum fired Hydrogen chloride (hydrochloric Ico6. pounds per hour, brick production rate, each) (ID acid) (7647-01-0) mbined Nos. ES-K3K and ES-K4K) Hydrogen fluoride (hydrofluoric acid 25.42 pounds per hour as mass of HF) (Component of 610 pounds per day 16984488/Fluorides) (7664-39-3) (24-hour), combined Mercury, vapor(Component of HGC) 0.0801 pounds per day (7439-97-6) 1(24-hour), combined a. Restrictions - To ensure compliance with the above limits, the following restrictions shall apply: i. The combined feed rate shall not exceed 54,800 pounds per hour for kilns 1 and 2 (ID Nos. ES-K1 and ES-K2), and ii. The combined feed rate shall not exceed 82,200 pounds per hour for kilns 3 and 4 (ID Nos. ES-K3K and ES-K4K). iii. The combined production limit shall not exceed 259,226 tons of fired brick per year when firing coal for kilns 3 and 4 (ID Nos. ES-K3K and ES-K4K). iv. The dry limestone adsorbers (DLA) (ID Nos. CD-K3DLA and CD-K4DLA) shall be operated for control of emissions of hydrogen chloride and hydrogen fluoride when the brick tunnel kilns (ID Nos. ES-K3K and ES-K4K) are in operation with following exception: (A)the Permittee shall be allowed to bypass the DLA(ID No. CD-K3DLA) for routine control device maintenance and continue operation of the brick tunnel kiln(ID No. ES-K3K) for up to 4% of the annual operating uptime of the kiln. (B) the Permittee shall be allowed to bypass the DLA (ID No. CD-K4DLA) for routine control device maintenance and continue operation of the brick tunnel kiln(ID No. ES- K4K) for up to 4% of the annual operating uptime of the kiln. V. The bypass damper position(open or closed) associated with DLAs (ID Nos. CD-K3DLA and CD-K4DLA) shall be monitored and recorded when the brick tunnel kilns (ID Nos. ES-K3K and ES-K4K) is in operation. vi. The limestone feeder setting of the DLAs (ID Nos. CD-K3DLA and CD- K4DLA) shall be maintained at or above 30 pounds per hour averaged over a 24-hour block period. vii. The DLAs (ID Nos. CD-K3DLA and CD-K4DLA) shall contain an adequate amount of limestone in the storage bin and hopper during operation. viii. The Permittee shall use the same grade of limestone from the same source in the DLAs (ID Nos. CD-K3DLA and CD-K4DLA) as used during the most recent performance test. Permit No. 04384R40 Page 10 ix. The Permittee shall monitor and record electronically the bypass damper position(open or closed) associated with the DLAs (ID Nos. CD-K3DLA and CD-K4DLA) at least every 15 minutes. In the alternative, a daily report showing the amount of open and/or closed time for the previous 24 hours may be generated from the plant computer. As a third alternative, manual log sheets may be used. The reason for each bypass event shall also be recorded in a logbook or by other electronic method. X. The Permittee shall verify that the limestone hopper and storage bins (located at the top of the DLAs) contain adequate limestone by performing a daily visual check and recording the results in a logbook or by other electronic method. xi. The Permittee shall record the limestone feeder setting daily in logbook or by other electronic method to verify that the feeder setting is being maintained at or above 30 pounds per hour. xii. The Permittee shall maintain records of the source and type of limestone utilized in the DLAs (ID Nos. CD-K3DLA and CD-K4DLA) during the most recent performance test in a logbook or by other electronic method. xiii. The Permittee shall monitor and record operating uptime of the brick tunnel kilns (ID Nos. ES-K3K and ES-K4K) and the downtime associated the routine control device maintenance of the DLAs (ID Nos. CD-K3DLA and CD-K4DLA). b. Reporting Requirements - For compliance purposes, within 30 days after each calendar year quarter, regardless of the actual emissions, the following shall be reported to the Regional Supervisor, DAQ: i. The maximum hourly combined feed rates for kilns 1 and 2 (ID Nos. ES-K1 and ES-K2) and for the kilns 3 and 4 (ID Nos. ES-K3K and ES-K4K) during each day of the reporting quarter. 12. CONTROL AND PROHIBITION OF ODOROUS EMISSIONS -As required by 15A NCAC 2D .1806 "Control and Prohibition of Odorous Emissions" the Permittee shall not operate the facility without implementing management practices or installing and operating odor control equipment sufficient to prevent odorous emissions from the facility from causing or contributing to objectionable odors beyond the facility's boundary. 13. LIMITATION TO AVOID 15A NCAC 2Q .0501 - Pursuant to 15A NCAC 2Q .0315 "Synthetic Minor Facilities," to avoid the applicability of 15A NCAC 2Q .0501 "Purpose of Section and Requirement for a Permit," as requested by the Permittee, facility-wide emissions shall be less than the following: Pollutant Emission Limit (Tons per consecutive 12-month period) PM10 100 Total HAPs 25 Individual HAPs 10 Permit No. 04384R40 Page 11 a. Operation Restrictions - To ensure emissions do not exceed the limitations above, the following restrictions shall apply: i. When any permitted equipment marked as "INACTIVE"in the emission source table becomes operational, these sources shall be operated such that facility-wide PM 10 emissions remain below 100 tons per year, total HAP emissions remain below 25 tons per year, and hydrogen chloride (HCl) and hydrogen fluoride (HF) emissions remain below 10 tons per year, each. b. Inspection and Maintenance Requirements - i. FABRIC FILTER REQUIREMENTS includingcartridge artridge filters, baghouses, and other dry filter particulate collection devices - Particulate matter emissions shall be controlled as described in the permitted equipment list. To comply with the provisions of this permit and ensure that emissions do not exceed the regulated limits, the Permittee shall perform periodic inspections and maintenance (I&M) as recommended by the manufacturer. In addition, the Permittee shall perform an annual (for each 12-month period following the initial inspection) internal inspection of each fabric filter system. ii. Cyclone Requirements - Particulate matter emissions shall be controlled as described in the permitted equipment list. To comply with the provisions of this permit and ensure that emissions do not exceed the regulatory limits, the Permittee shall perform an annual (for each 12-month period following the initial inspection) inspection of the cyclone system. In addition, the Permittee shall perform periodic inspections and maintenance (I&M) as recommended by the manufacturer. c. Recordkeeping Requirements - i. The Permittee shall record the date that any permitted equipment marked as "INACTIVE"in the emission source table becomes operational. Upon such date, the Permittee shall begin to record monthly and total annually the PM 10, total HAP, hydrogen chloride (HCl) and hydrogen fluoride (HF) emissions from these sources. ii. A logbook(in written or electronic format) shall be kept on site for each control device and made available to Division of Air Quality personnel upon request. The Permittee shall record all inspection, maintenance and monitoring requirements listed above in the logbook. Any variance from the manufacturer's recommendations shall be investigated with corrections made and date of actions recorded in the logbook. d. Reporting Requirements - i. The Permittee shall notify the Division of Air Quality of the date that any permitted equipment marked as "INACTIVE"in the emission source table becomes operational. The notification shall be postmarked within 15 days after such date. ii. Within 30 days after each calendar year, regardless of the actual emissions, the Permittee shall submit the following emissions and/or operational data listed below. The data should include monthly and 12-month totals for the previous 12-month period. Permit No. 04384R40 Page 12 A. The facility-wide PM10, total HAP, hydrogen chloride (HCI) and hydrogen fluoride (HF) emissions. 14. TOXIC AIR POLLUTANT EMISSIONS LIMITATION REQUIREMENT -Pursuant to 15A NCAC 2Q .0711 "Emission Rates Requiring a Permit," for each of the below listed toxic air pollutants (TAPs), the Permittee has made a demonstration that facility-wide actual emissions, where one or more emission release points are obstructed or non-vertically oriented, do not exceed the Toxic Permit Emission Rates (TPERs) listed in 15A NCAC 2Q .0711(a). The facility shall be operated and maintained in such a manner that emissions of any listed TAPS from the facility, including fugitive emissions, will not exceed TPERs listed in 15A NCAC 2Q .0711(a). a. A permit to emit any of the below listed TAPS shall be required for this facility if actual emissions from all sources will become greater than the corresponding TPERs. b. PRIOR to exceeding any of these listed TPERs, the Permittee shall be responsible for obtaining a permit to emit TAPs and for demonstrating compliance with the requirements of 15A NCAC 2D .1100 "Control of Toxic Air Pollutants". c. In accordance with the approved application, the Permittee shall maintain records of operational information demonstrating that the TAP emissions do not exceed the TPERs as listed below: Chronic Acute Acute Pollutant Carcinogens Toxicants Systemic Irritants (lb/yr) (lb/day) Toxicant (lb/hr) s (lb/hr) Bromine (7726-95-6) �— 0.052 Carbon disulfide (75-15-0) F 3.9 F_F__ Chromium(VI)Non-Specific Compounds, as 0.0056 Chrom(VI) (Component CRC) (NSCR6) Cresol (mixed isomers) (1319-77-3) F— 0.56 r Dichlorobenzene(p), 1,4- (106-46-7) F F 16.8 Ethyl mercaptan (75-08-1) F— 0.025 Formaldehyde (50-00-0) F-F-- 0.04 Hexane isomers, except n-hexane (HEXANEISO) FF__ 92 Hexane, n- (110-54-3) F 23 MIBK(methyl isobutyl ketone) (108-10-1) F 52 F_— 7.6 Manganese & compounds (MNC) F 0.63 F__F__ Methyl mercaptan (74-93-1) �F 0.013 Nitrobenzene (98-95-3) 1.3 F 0.13 PCB (polychlorinated biphenyls) (1336-36-3) 1 5.6 F_F_F_ Pentachlorophenol (87-86-5) F 0.063 0.0064 �— Styrene (100-42-5) 2.7 Permit No. 04384R40 Page 13 B. GENERAL CONDITIONS AND LIMITATIONS 1. In accordance with G.S. 143-215.108(c)(1), TWO COPIES OF ALL DOCUMENTS, REPORTS, TEST DATA, MONITORING DATA,NOTIFICATIONS, REQUESTS FOR RENEWAL, AND ANY OTHER INFORMATION REQUIRED BY THIS PERMIT shall be submitted to the: Regional Supervisor North Carolina Division of Air Quality Raleigh Regional Office 3800 Barrett Drive Raleigh,NC 27609 919-791-4200 For identification purposes, each submittal should include the facility name as listed on the permit, the facility identification number, and the permit number. 2. RECORDS RETENTION REQUIREMENT - In accordance with 15A NCAC 2D .0605, any records required by the conditions of this permit shall be kept on site and made available to DAQ personnel for inspection upon request. These records shall be maintained in a form suitable and readily available for expeditious inspection and review. These records must be kept on site for a minimum of 2 years,unless another time period is otherwise specified. 3. ANNUAL FEE PAYMENT -Pursuant to 15A NCAC 2Q .0203(a), the Permittee shall pay the annual permit fee within 30 days of being billed by the DAQ. Failure to pay the fee in a timely manner will cause the DAQ to initiate action to revoke the permit. 4. EQUIPMENT RELOCATION- In accordance with 15A NCAC 2Q .0301, a new air permit shall be obtained by the Permittee prior to establishing, building, erecting,using, or operating the emission sources or air cleaning equipment at a site or location not specified in this permit. 5. REPORTING REQUIREMENT - In accordance with 15A NCAC 2Q .0309, any of the following that would result in previously unpermitted, new, or increased emissions must be reported to the Regional Supervisor, DAQ: a. changes in the information submitted in the application regarding facility emissions; b. changes that modify equipment or processes of existing permitted facilities; or c. changes in the quantity or quality of materials processed. If appropriate, modifications to the permit may then be made by the DAQ to reflect any necessary changes in the permit conditions. In no case are any new or increased emissions allowed that will cause a violation of the emission limitations specified herein. 6. In accordance with 15A NCAC 2Q .0309, this permit is subject to revocation or modification by the DAQ upon a determination that information contained in the application or presented in the support thereof is incorrect, conditions under which this permit was Permit No. 04384R40 Page 14 granted have changed, or violations of conditions contained in this permit have occurred. In accordance with G.S. 143-215.108(c)(1), the facility shall be properly operated and maintained at all times in a manner that will effectuate an overall reduction in air pollution. Unless otherwise specified by this permit, no emission source may be operated without the concurrent operation of its associated air cleaning device(s) and appurtenances. 7. In accordance with G.S. 143-215.108(c)(1), this permit is nontransferable by the Permittee. Future owners and operators must obtain a new air permit from the DAQ. 8. In accordance with G.S. 143-215.108(c)(1), this issuance of this permit in no way absolves the Permittee of liability for any potential civil penalties which may be assessed for violations of State law which have occurred prior to the effective date of this permit. 9. In accordance with G.S. 143-215.108(c)(1), this permit does not relieve the Permittee of the responsibility of complying with all applicable requirements of any Federal, State, or Local water quality or land quality control authority. 10. In accordance with 15A NCAC 2D .0605, reports on the operation and maintenance of the facility shall be submitted by the Permittee to the Regional Supervisor, DAQ at such intervals and in such form and detail as may be required by the DAQ. Information required in such reports may include, but is not limited to,process weight rates, firing rates, hours of operation, and preventive maintenance schedules. 11. A violation of any term or condition of this permit shall subject the Permittee to enforcement pursuant to G.S. 143-215.114A, 143-215.11413, and 143-215.114C, including assessment of civil and/or criminal penalties. 12. Pursuant to North Carolina General Statute 143-215.3(a)(2), no person shall refuse entry or access to any authorized representative of the DAQ who requests entry or access for purposes of inspection, and who presents appropriate credentials, nor shall any person obstruct, hamper, or interfere with any such representative while in the process of carrying out his official duties. Refusal of entry or access may constitute grounds for permit revocation and assessment of civil penalties. 13. In accordance with G.S. 143-215.108(c)(1), this permit does not relieve the Permittee of the responsibility of complying with any applicable Federal, State, or Local requirements governing the handling, disposal, or incineration of hazardous, solid, or medical wastes, including the Resource Conservation and Recovery Act(RCRA) administered by the Division of Waste Management. 14. PERMIT RETENTION REQUIREMENT - In accordance with 15A NCAC 2Q .0110, the Permittee shall retain a current copy of the air permit at the site. The Permittee must make available to personnel of the DAQ,upon request, the current copy of the air permit for the site. 15. 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. Permit No. 04384R40 Page 15 16. PREVENTION OF ACCIDENTAL RELEASES - GENERAL DUTY - Pursuant to Title I Part A Section 112(r)(1) of the Clean Air Act "Hazardous Air Pollutants - Prevention of Accidental Releases -Purpose and General Duty," although a risk management plan may not be required, if the Permittee produces, processes, handles, or stores any amount of a listed hazardous substance, the Permittee has a general duty to take such steps as are necessary to prevent the accidental release of such substance and to minimize the consequences of any release. This condition is federally-enforceable only. 17. GENERAL EMISSIONS TESTING AND REPORTING REOUIREMENTS -If emissions testing is required by this permit, or the DAQ, or if the Permittee submits emissions testing to the DAQ in support of a permit application or to demonstrate compliance, the Permittee shall perform such testing in accordance with 15A NCAC 2D .2600 and follow all DAQ procedures including protocol approval, regional notification, report submittal, and test results approval. Additionally, in accordance with 15A NCAC 2D .0605, the Permittee shall follow the procedures for obtaining any required audit sample and reporting those results. Permit issued this the 29th of July, 2021. NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION Taylor Hartsfield, EIT, CPM Regional Supervisor By Authority of the Environmental Management Commission Air Permit No. 04384R40 ATTACHMENT to Permit No. 04384R40, July 29, 2021 Insignificant/Exempt Activities Source Exemption Source of ource of Title V Regulation I TAPs? Pollutants? IS-4 - Screened clay conveying and handling 2Q .0102 (h)(5) No Yes operation for Kiln 3 and 4 IES-CP - Open clay storage piles 12Q .0102 (h)(5) I No I Yes IES-K4F.I - Box feeder for Line 4 12Q .0102 (h)(5) I No I Yes IES-T1 - 350 gallon brick oil tank 12Q .0102 (h)(5) I Yes I No I-F-CH-AF -Apron feeder 2Q .0102 (h)(5) I No I Yes I-F-CH-H - Hopper(50 ton capacity) 12Q .0102 (h)(5) I No I Yes IES-T5 - 1,000 gallon gasoline storage tank 12Q .0102 (h)(5) I Yes I No IES-T2 - 350 gallon gear oil tank 12Q .0102 (h)(5) I Yes I No IES-T3 - 275 gallon waste oil tank 12Q .0102 (h)(5) I Yes I No IES-T4 - 1,000 gallon diesel tank 12Q .0102 (h)(5) 1 Yes I No IES-F-CH6 - Existing raw material handling and 2Q .0102 (h)(5) No Yes conveying operations IES-F-CO-2 -Reclaimer(coating operations) 12Q .0102 (h)(5) No Yes IES-RECLAIM - Reclaimer building storage piles 12Q .0102 (h)(5) No Yes IES-K4F.2 - conveying system for line 4 12Q .0102 (h)(5) No Yes IES-K4F.3 - storage tank for line 4 12Q .0102 (h)(5) Yes No IES-VS3 - Hi-Vac vacuum system for Kiln 3 12Q .0102 (h)(5) No Yes IES-F-CO-CI, IES-F-CO-C2, IES-F-CO-C3, IES-F- CO-C4, IES-F-CO-05 - Five conveyors (coating 2Q .0102 (h)(5) No No operations) IES-VS4, IES-VS5 —Two package-type kiln car vacuuming systems 2Q .0102 (h)(5) No Yes IF-BH-MR-C, IF-BH-MR-DH - One dump hopper 2Q 0102 (h)(5) No Yes and one conveyor at the Brickhaven site IS-7.1, IS-7.2, IS-7.3, IS-7.4, IS-7.5, IS-7.6, IS-7.7, 2Q 0102 (h)(5) No Yes IS-7.8 - Six sand coating piles and two conveyers IS-8.1, IS-8.2, IS-8.3, IS-8.4, IS-8.5, IS-8.6, IS-8.7, IS-8.8, IS-8.9 -Kiln 3 raw material handling 2Q .0102 (h)(5) No Yes operations consisting of a storage pile, box feeder, six conveyors, and a storage bin INACTIVE SOURCES IES-SD (INACTIVE) - Wood receiving, non- pneumatic handling and conveying and storage 2Q .0102 (h)(5) No Yes operations IS-3 (INACTIVE) - Screened Clay Conveying and 2Q 0102 (h)(5) No Yes Handling Operation for Kiln I and 2 I-ES-KIDI (INACTIVE) -brick dryer associated with Kiln 1 2Q .0102 (h)(5) No Yes ATTACHMENT to Permit No. 04384R40, July 29, 2021 Source Exemption Source of ource of Title V Regulation TAPs? Pollutants? I-ES-K2D1 (INACTIVE) -brick dryer associated 2Q .0102 (h)(5) No Yes with Kiln 2 IES-VS 1, IES-VS2 (INACTIVE) - Two package- 2Q .0102 (h)(5) No Yes type kiln car vacuuming systems I. Because an activity is exempted from being required to have a permit or permit modification does not mean that the activity is exempted from an applicable requirement or that the owner or operator of the source is exempted from demonstrating compliance with any applicable requirement. 2. When applicable, emissions from stationary source activities identified above shall be included in determining compliance with the permit requirements for toxic air pollutants under 15A NCAC 2D .I 100 "Control of Toxic Air Pollutants" or 2Q .0711 "Emission Rates Requiring a Permit." 3. Sample permit conditions showing the regulatory requirements for exempt sources subject to NESHAP,NSPS, and NCAC rules may be found here: https:Hdeg.nc.gov/agpermitconditions