Loading...
HomeMy WebLinkAboutAQ_F_0400043_20200910_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: 09/22/2020 County/FIPS:Anson/007 Facility Data Permit Data Triangle Brick Company-Wadesboro Brick Manufacturing Plant Permit 08179/Tl 1 US Hwy 52 Issued 7/13/2018 Wadesboro,NC 28170 Expires 6/30/2023 Lat: 35d 1.1463m Long: 80d 5.1235m Class/Status Title V SIC: 3251 /Brick And Structural Clay Tile Permit Status Active NAICS: 327121 /Brick and Structural Clay Tile Manufacturing Current Permit Application(s)None Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact SIP/Title V Howard Brown,Jr. Howard Brown,Jr. Howard Brown,Jr. NSPS: Subpart COO, Subpart UUU President and CEO President and CEO President and CEO (919)544-1796 (919)544-1796 (919)544-1796 Compliance Data Comments: Inspection Date 09/10/2020 Inspector's Name Evangelyn Lowery-Jacobs Inspector's Signature: _ Operating Status Operating G Compliance Code Compliance- inspection Action Code FCE Date of Signature: 09/Z7_12o ZU On-Site Inspection Result Compliance Total Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PM10 * HAP 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 2016 13.19 22.02 9.26 4.58 42.38 10.99 9503.74 * Highest HAP Emitted(inpounds) Five Year Violation History: None Date Letter Type Rule Violated Violation Resolution Date Performed Stack Tests since last FCE:None Date Test Results Test Method(sl Source(s)Tested Triangle Brick Company-Wadesboro Brick Manufacturing Plant Compliance Inspection Report Page 2 of 12 I. DIRECTIONS TO SITE: Triangle Brick is located on US 52 about 4 miles north of Wadesboro, NC, Anson County. From FRO, take US 401(Raeford Rd.) south to US 74; turn right onto US 74 West. Follow US 74 thru Wadesboro. On the west side of Wadesboro, turn right, following US 52 north. Go approximately 4 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). IL 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 very cool robot) and stored prior to purchase and shipment. IV. INSPECTION SUMMARY: On 10 September 2020, 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 91 (K-1) at approx. 12 tons/hr. each. Kiln #2 (K-2)has not operated since April 2020, resulting in a decrease in employees. 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 MACT). Facility records appeared complete and in accordance with the current requirements outlined in their air quality permit No. 008179TI 1. 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. He detailed factors like feeder rate settings and the interface used to track the status and settings for the device. 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 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 Triangle Brick Company-Wadesboro Brick Manufacturing Plant Compliance Inspection Report Page 3 of 12 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: Emission Control Source ID ; Emission Source Description Device Control Device No. ID No. Description Two Brick Tunnel Kilns One natural gas/No. 2 fuel oil/No. 6 fuel oil-fired Dry Limestone Brick Tunnel Kiln(29.0 tons per hour material output FK- t [CD-KI Adsorber(DLA) rate,42.8 million Btu per hour heat input rate) Operating at-12TPH Operating, 0%VE One natural gas/No. 2 fuel oil/No. 6 fuel oil-fired Dry Limestone K 2 Brick Tunnel Kiln (29.0 tons per hour material output CD-K2 Adsorber(DLA) rate, 42.8 million Btu per hour heat input rate) Not Operating Not Operating Rotary Coatings Dryer SD-1 One natural gas-fired Rotary Coatings Dryer(8.1 tons of clay per hour material input rate, 0.3 million Btu N/A N/A NSPS UUU per hour heat input rate) Primary Crushing Plant and Associated Conveyances PC-1 and Two shale feeders N/A N/A PC-2 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 PC-7 One conveyor under PC-3 and PC-5 N/A N/A NSPS 000 Triangle Brick Company-Wadesboro Brick Manufacturing Plant Compliance Inspection Report Page 4 of 12 Emission `. Control Control Device Source IDF Emission Source Description Device Description No. ID No. PC-8 -- One conveyor under PC-4 and PC-6 N/A N/A F PS 000 PC-9 One cross-over conveyor N/A N/A FNSPS00 0 One shuttle conveyor N/A N/A FXSPPCS-10100 Two Secondary Clay Grinding Plants and Associated Conveyances CG-1 I One clay feeder N/A N/A CG-2 One conveyor belt to scalping screen N/A N/A NSPS 000 CG-3 One scalping screen N/A N/A NSPS 000 One return conveyor belt for oversize from screens N/A N/A CG-4 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 FNS PS 000 CG-8 One conveyor belt to finish screens N/A N/A , NSPS 000 CG-10 through Four finish screens N/A N/A CG-13 NSPS 000 CG-14 One fines conveyor belt under screens N/A N/A FNSPS 000 CG-15 One conveyor belt to storage bins N/A N/A NSPS 000 Triangle Brick Company-Wadesboro Brick Manufacturing Plant Compliance Inspection Report Page 5 of 12 Emission ' Control Control Device Source ID' Emission Source Description Device Description No ID No. CG-16 r ��One conveyor belt over storage bins F N/A ( N/A NSPS 000 CG-17 through CG-21 Five storage bins N/A N/A NSPS 000 [[ CG-22 through CG-26 Five feeders under storage bins N/A N/A NSPS 000 CG-27 One conveyor in front of storage bins N/A N/A NSPS 000 CG-28 One conveyor to pug mill N/A N/A NSPS 000 F CG-29 One clay feeder N/A f 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 FCG-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 F One conveyor belt to finish screens N/A N/A NSPS 000 Triangle Brick Company-Wadesboro Brick Manufacturing Plant Compliance Inspection Report Page 6 of 12 Emission Control Control Device Source ID Emission Source Description Device Description No. ID No. 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 NSPS 000 One conveyor be to storage bins N/A N/A CG-43 One conveyor belt over storage bins N/A N/A NSPS 000 CG-44 through CG-48 Five storage bins N/A N/A NSPS 000 [-[ CG-49 through CG-53 Five feeders under storage bins N/A N/A NSPS 000 CG-54 One conveyor in front of storage bins N/A N/A NSPS 000 CG-55 f NSPS 000 One conveyor to pug mill N/A N/A Loam/Sawdust Preparation Operation and Associated Conveyances LS-1 Loam/sawdust feeder N/A N/A LS-2 One conveyor from loam/sawdust feeder NSPS 000 F to finish screens N/A N/A 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 Page 7 of 12 Emission j Control Control Device Source ID Emission Source Description Device Description No. ID No. 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 F N/A NSPS 000 bunker belt conveyor LS 8- — - - One belt conveyor to bunker N/A N/A __F F NSPS 000 LS-9 One storage bunker N/A N/A NSPS 000 LS-10 One sawdust screen N/A N/A NSPS 000 L1 NSPS S-1 -F One conveyor to storage bins N/A N/A 000 LS-12 One oversize conveyor from sawdust screen N/A N/A NSPS 000 VI. INSIGNIFICANT ACTIVITIES per 15A NCAC 02Q .0503(8) Emission Source Emission Source Description �No. 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 "A"storage tank Triangle Brick Company- Wadesbom Brick Manufacturing Plant Compliance Inspection Report Page 8 of 12 VII. APPLICABLE AIR QUALITY REGULATIONS: A. 15A NCAC 2D .0515 PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES—Particulate emissions from each kiln, K-1 and K-2, shall not exceed 39.14 lbs./hour at a production rate of 29 tons/hour(4.1 x P 0,67). 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 9113116 test was 3.78 lb.1hr. The facility was operating at 25.17 TPH with DLA control. The calculated PMemission limit at this operating rate is 35.6 lb./hr. This demonstrated emission rate is forfilterable PMonly, 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 0711412020 and K-2 on 0711612020. The most recent semiannual report was received on 0712812020 time 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 92 fuel oil as back up fuel during NG curtailment. The last shipment of No. 6 fuel oil received at the facility(S=1.36%) was in 2011 and none of it has been combusted to date. The facility did burn approx. 12,600 gals of 42 fuel oil in Nov 2016 and Jan 2017 due to curtailment. The rotary coatings dryer SD-1 started operation in June 2005 and is designed to operate solely on natural gas. The AP-42 SO2 emission factors for NG is 0.0006lb,/MMBtu and for No.2 fuel oil is 0.0231b.IMMBtu. This plant operates primary on NG; therefore, SO2 emissions are less than any 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 0712812020 and appeared complete and valid. D. 15A NCAC 2D .0524 NEW SOURCE PERFORMANCE STANDARDS SUBPART UUU— For the Rotary coatings dryer(SD-1): VE shall not be greater than 10%, the Permittee shall observe the source daily for any VE;the Permittee shall inspect and maintain the rotary coatings dryer in accordance with the manufacturer's recommendation and shall perform a semi-annual internal inspection for deterioration, damage and leaks; and submit semi-annual summary reports to DAQ. APPEARED INCOMPLIANCE—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 Triangle Brick Company-Wadesboro Brick Manufacturing Plant Compliance Inspection Report Page 9 of 12 during a previous inspection. The last semi-annual inspection on the dryer was conducted on 0711412020. The records appeared complete and valid. The most recent semi-annual report was received on 0712812020 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. Mr. Gibson stated that he and Mr. Meggs have been to smoke school to enable them to identify 10%opacity. The most recent semiannual report was received on 0712812020 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 same building). One conveyor in the grinding operation is in separate building(milling bldg.)from the rest of the subject sources which require VE observations. Observations are made at both openings,for each side of the grinding building, and the mill building, monthly. 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 0712812020 and appeared complete and valid. G. 15A NCAC 2D .0524 NEW SOURCE PERFORMANCE STANDARDS SUBPART 000- For the loam/sawdust preparation area, loam screen, loam crusher, storage bunker, sawdust screen, and conveyors(ID Nos. LS-2 through LS-12), non-stack VE shall not be greater than 10%except for crushers not greater than 15%; Permittee shall observe building openings monthly for any VE. Permittee shall submit semiannual reports to DAQ. APPEARED IN COMPLIANCE—There are two openings to each half of the grinding building. Observations are made at both openings,for each side of the grinding building, monthly. The monthly observation records all indicated "normal,"which is then defined by the facility as "No Visible Emissions. " The sawdust operations were not operating during the inspection and zero (0) visible emissions were observed from the building openings. The most recent semiannual report was received on 0712812020 and appeared complete and valid. Triangle Brick Company-Wadesboro Brick Manufacturing Plant Compliance Inspection Report Page 10 of 12 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 K-I at approx. 12 TPH. K-2 has not operated since April 2020. The highest hourly rate in the last 12 months was approximately 16 tons for K-1 and 9 tons for K-2. These process rates are below the permit limits requiring less than 29 TPH and indicates compliance. The most recent semiannual report was received on 0711612020 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 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 document when 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 HAPS by the DLAs reduce the actual emissions to less than 10125 TPY HAPS. 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. Meggs indicated the facility receives automatic deliveries of limestone 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 Triangle Brick Company-Wadesboro Brick Manufacturing Plant Compliance Inspection Report Page 11 of 12 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 0712812020 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 SOZ emissions and fuel combustion quantities. K-2 has semi-annual summary reporting of SOZ emissions and fuel combustion quantities. APPEARED INCOMPLLINCE— The facility burns NG with low sulfur No. 2 fuel oil as back up only during NG curtailment. The facility was curtailed in Nov 2017 and Jan 2018 and burned approx. 12,600 gals offuel 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 tons for K-1 and 9 tons for K-2. The most recent report was received on 0712812020 and indicated compliance. M. PERMIT GENERAL CONDITION LA 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 213 .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 0112912020 and appeared complete and valid. O. GENERAL CONDITION X—ANNUAL EMISSION INVENTORY REQUIREMENTS—The permittee shall submit an Annual Emission Inventory postmarked on or before June 30'h of each year. APPEARED IN COMPLLANCE—The facility's 2018 AQEI was received on 0613012020 and appeared to be complete and accurate. Triangle Brick Company-Wadesboro Brick Manufacturing Plant Compliance Inspection Report Page 12 of 12 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 INCOMPLIANCE—Mr. Gibson stated that no dust complaints had been received by the facility, and FRO has not received any dust complaints. There did not appear to be any issues with fugitive dust from our observations on site. The parking lot and general area around the process is paved and no dust was observed. VIII. NON-COMPLIANCE HISTORY SINCE 2010: 05/11/2017 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. 008179T1 l during the inspection on 09/10/2020. XI. PINK SHEET ADDITIONS: None. /elj