AQ_F_1900077_20190731_CMPL_InspRpt

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NORTH CAROLINA DIVISION OF Raleigh Regional Office
AIR QUALITY Triangle Brick Company-Merry Oaks Brick
Manufacturing Plant
Inspection Report NC Facility ID 1900077
Date: 08/01/2019 County/FIPS: Chatham/037
Facility Data Permit Data
Triangle Brick Company-Merry Oaks Brick Manufacturing Plant Permit 06897/T12
294 King Rd Issued 5/14/2018
Moncure,NC 27559 Expires 4/30/2023
Lat: 35d 38.5250m Long: 79d 0.0560m Class/Status Title V
SIC: 3251 /Brick And Structural Clay Tile Permit Status Active
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
Ricky Merritt Howard Brown,Jr. Ricky Merritt NSPS: Subpart 000, Subpart UUU
Director of Engineering President and CEO Director of Engineering
[phone] [phone] [phone]
Compliance Data
Comments: Facility appears to be compliant.
Inspection Date 07/31/2019
Inspector's Name Stanley Williams
Inspector's Signature:-`�O�G>�� Operating Status Operating
Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: S �.20/q On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2017 61.67 4.48 9.11 5.73 41.30 59.53 2245.56
2016 64.92 4.58 9.31 6.12 42.28 47.96 36459.00
2015 -34.20 4.85 9.07 5.29 40.57 25.35 58273.92
*Highest HAP Emitted(in pounds)
Five Year Violation History:
Date Letter Tyne Rule Violated Violation Resolution Date
05/12/2017 NOV Avoidance 21).1109 1120)Case-by-Case Maximum 06/12/2017
Achievable Control Technology
Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested
(I)DIRECTIONS:Triangle Brick Company's Merry Oaks Plant is located off US-1 South in Merry Oaks, Chatham County,
North Carolina. From Raleigh,take US-1 South to exit 84 onto Old US-1 South. Turn right onto Old US 1, follow
approximately 1/4 mile, and take a left onto SR 1912,Christian Chapel Church Road. Cross the train tracks and turn left onto
SR 1911,King Road. The facility is easily visible from King Road&US-1.

(In FACILITY DESCRIPTION: The Merry Oaks Plant operates three brick kilns (Kiln ID Nos. 1, 2,3) and historically has
manufactured approximately 4 million bricks per week. Kilns 1 and 2 were installed in 1991 and each has a capacity of 24
cars/day. Each brick car serving Kilns 1 and 2 can hold a maximum of 6,408 bricks. Using a conservative factor of 4.5
pounds/brick,the ton per hour process rate for Kilns 1 and 2 calculates to 13.8 tons/hour. The maximum permitted production
rate for each kiln is 14.5 tons/hour. Kiln 3 began operation in 1999. According to staff,the kiln has a capacity for 25 cars/day.
The brick cars serving Kiln 3 can hold 18,144 brick each. The ton per hour process rate for kiln 3 calculates to 27.2 tons per
hour. The maximum permitted production rate for Kiln 3 is 29 tons/hour. Standard personal protective equipment for this
facility would include,but not limited to,hard hat,safety glasses,hearing protection, and safety shoes.
(III)INSPECTION SUMMARY: On July 31, 2019,I(Stan Williams)met with Mr. Buck Reece,Director of Manufacturing
for Triangle Brickifor the purpose of conducting an air quality permit compliance inspection. At the time of this compliance
inspection,the facility was operating Kiln 3 at a 15 car per day schedule. Mr. Reece and I reviewed all the permit required
monitoring and recordkeeping requirements of revision T 12,the permit in effect at the time of this inspection. Only Kiln 3 was
operating at the time of my inspection and the facility appeared to be operating well from an air quality standpoint with no
visible emissions(VE) from the Kiln 3 stack and no odorous emissions(OE)from the facility. The sky conditions at the time of
the inspection were sunny.
Comments about observations made during the inspection are provided below for each of the emission sources and specific air
quality regulations listed in the facility's current air permit.
(IV) PERMITTED EMISSION SOURCES: At the time of the inspection, Triangle Brick Company was operating under Air
Quality Permit No. 06897T12, which became effective on May 14, 2018, expires on April 30, 2023, and includes the following
emission sources and control devices:
(a) Primary Crushing and Associated Conveyance including: Shale Feeder (ID No. PC-1) and NSPS affected facilities
consisting of a scalp screen(ID No. PC-2),jaw crusher(ID No. PC-3), and three conveyors (ID Nos. PC-4,PC-5, and PC-6);
This equipment was operating at the time of the inspection. This equipment provides the raw material for all three kilns. The
raw material used comes either directly from that site or another close site(owned by Triangle Brick). The equipment appeared
to be in sound condition.
(b) Clay Grinding Operations (Feeders (ID Nos. CG-1 and CG-29)and NSPS affected facilities consisting of conveyors,
screens, and hammer mills(ID Nos. CG-2 thru CG-20, CG-22 thru CG-28, and CG-30 thru CG-49);
This eNc moment was keratin at the time of the inspection. This equipment helps prepare the raw material for all three kilns.
The equipment appeared to be in sound condition.
(c)Brick Tunnel Kilns (ID Nos. K-1, K-2, and K-3; 14.5, 14.5, and 29 tons per hour fired-brick capacity, respectively) with
associated dry lime cascade adsorber units;
Kiln K-3 was observed in operation and was on a fifteen(15)car per day schedule at the time of my visit. Kiln K-1 and Kiln K-
2 were not operating.
(d)Natural Gas Fired Rotary Coatings Dryer(ID Nos. SD-1).
This equipment was not in operation at the time of the inspection.
(V)APPLICABLE AIR QUALITY REGULATIONS: As is the case with all Title V permits,Air Quality Permit No.
06897T12 lists all of the air quality regulations that apply to each of the permitted emission sources. To avoid redundancy in
this report,the applicable air quality regulations are discussed individually, and the permitted emission sources that are subject
to a specific regulation are noted.

(1) 15A NCAC 2D.0515:PARTICULATE FROMMISCELLANEOUS INDUSTRIAL PROCESSES—The following emission
sources are subject to 2D.0515: The shale feeder(ID No. PC-1), clay feeders (ID Nos. CG-I and CG-29), and brick kilns (ID
Nos. K-1, K-2, and K-3).
IN COMPLIANCE—The particulate emission limit for each of the subject emission sources is determined based on the
individual process weight rates for each source. According to previous permit reviews, all of these sources should meet the
applicable 15A NCAC 2D .0515 emission limit under normal operating conditions. No monitoring, recordkeeping, or reporting
is required for the particulate matter emissions from these sources.
(2) 15A NCAC 2D.0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES—The following emission sources
are subject to 2D.0516: The three brick kilns (ID Nos. K-1, K-2, &K-3)and the rotary coatings dryer(ID Nos. SD-1).
IN COMPLIANCE — The sulfur dioxide emission limit for each of the subject emission sources is 2.3 pound per million Btu
heat input. There is no testing, monitoring, record keeping, or reporting requirements for sulfur dioxide emissions from the
firing of natural gas and No. 2 fuel oil. To demonstrate compliance with the sulfur dioxide limitation when firing No. 6 fuel oil,
the facility is required to monitor all fuel oil shipments to the plant site to ensure that the sulfur content does not exceed 2.1
percent by weight. Records of fuel oil certifications must be kept on site. The facility is also required to submit a semiannual
summary report and clearly document any deviations to the monitoring and record keeping requirements. Based on a review of
facility records and RRO files, the facility appeared to be complying with the requirements of 15A NCAC 2D .0516. The
facility is utilizing natural gas as their primary fuel and the SO2 emission levels of natural gas would be far below the limits.
(3) 15A NCAC 2D.0521: CONTROL OF VISIBLE EMISSIONS—The following emission sources are subject to 2D.0521: The
shale feeder(ID No. PC-1), the clay feeders (ID Nos. CG-1 and CG-29), and the three brick kilns (ID Nos.K 1,K-2, &K-3).
IN COMPLIANCE—The visible emission limit for each of the subject emission sources is 20 percent opacity when averaged
over a six-minute period. No visible emissions were noted from any of the permitted emission sources during the inspection.
No visible emission testing is required by the facility's air permit. The permit does require the facility to perform monthly
visible emissions observations,record the results of the VE evaluations in a logbook, and submit a summary report of the daily
observations on a semiannual basis. According to the logbooks of visible emissions observations that I reviewed for this
equipment, monthly observations are being performed by Mr. Reece and none of the observations indicated anything but
"normal". The facility has established"normal"as no visible emissions.
(4) 15A NCAC 2D.0524: NEW SOURCE PERFORMANCE STANDARDS(40 CFR 60 SUBPART 000-STANDARDS OF
PERFORMANCE FOR NONMETALLIC MINERAL PROCESSING PLANTS)—The following emission sources are subject to
2D.0524, Subpart 000: Scalp screen (ID No. PC-2),jaw crusher(ID No. PC-3), conveyor under PC-2 &PC-3 (ID No. PC-
4), cross-over conveyor(ID No. PC-5), shuttle conveyor(ID No. PC-6), hammer mills (ID Nos. CG-6& CG-34), screens,
conveyor belts, &feeders (ID Nos. CG-2 thru CG-20;ID Nos. CG-22 thru CG-28;ID Nos. CG-30 thru CG-49; respectively).
IN COMPLIANCE — To comply with the requirements of Subpart 000, the facility must maintain particulate and visible
emissions below the source specific limits defined in the permit. The permit requires the facility to conduct monthly visible
observations on all NSPS-affected equipment. The facility must also record the results of the monthly observations in a logbook
and submit a summary report of all visible emission observations on a semiannual basis. Based on a review of facility records,
the facility appeared to be complying with the requirements of 15A NCAC 2D .0524, Subpart 000.
(5) 15A NCAC 2D.0524: NEW SOURCE PERFORMANCE STANDARDS(40 CFR 60 SUBPART UUU-STANDARDS OF
PERFORMANCE FOR CALCINERS AND DRYERSINMINERAL INDUSTRIES)—The following emission source is subject to
2D.0524, Subpart UUU: The rotary coatings dryer(ID Nos. SD-1).
IN COMPLIANCE—To comply with the requirements of Subpart UUU,the facility must maintain particulate and visible
emissions below the source specific limits defined in the permit. The rotary coatings dryer started operation on July 5, 2006.
The permit requires the facility to conduct a performance test within 180 days of initial startup. This test was completed on
February 2, 2007, and the results demonstrated compliance with the applicable standards. The permit also requires the facility
to conduct monthly visible observations and perform periodic inspections and maintenance as needed and as recommended by

the manufacturer(at a minimum a semiannual internal inspection) of the rotary sand dryer. The facility must also record the
results of the monthly observations and the results of inspection and maintenance in a logbook and submit a summary report of
all visible emission observations and the periodic inspections and maintenance on a semiannual basis. Based on a review of
facility records and RRO files,the facility appeared to be complying with the requirements of 15A NCAC 2D .0524, Subpart
UUU.
(6) 15A NCAC 2D.1100 and 2Q.0711: TOXIC AIR POLL UTANT REQ UIREMENTS—The following emission sources are
subject to 2D.1100 and 2Q.0711: The three brick kilns (ID Nos. K-1, K 2, and K-3).
IN COMPLIANCE-In conjunction with a prior permit application,the permittee submitted air modeling results tha
demonstrated that emissions of the Toxic Air Pollutants (TAPs) listed in the permit were below state Ambient Air Standards
(AALs)beyond the fence line of the facility. To comply with 15A NCAC 2D .1100,the permittee must maintain actual
emissions of these TAPS below the emission limits outlined in the permit.
To comply with 15A NCAC 2Q .0711,the Permittee must ensure that emissions of specified TAPs do not exceed the Toxic
(Permit Emission Rates (TPERs) specified in the permit. If any of the TPERs are exceeded,the facility must obtain a permit to
emit TAPs and demonstrate compliance with state AALs. According to the facility's 2017 annual emissions inventory, all
actual toxic pollutant emissions are well below the applicable emission limits. Their 2018 annual emissions inventory had not
been reviewed and approved at the time of this inspections but compliance is expected.
7) 15A NCAC 2D.1806: CONTROL AND PROHIBITION OF ODOROUS EMISSIONS(STATE ONLY REQUIREMENT) The
following emission sources are subject to 2D.1806: All facility-wide affected emission sources.
IN COMPLIANCE—To comply with 2D .1806,the Permittee shall not operate the facility without implementing management
practices or installing and operating odor control equipment sufficient to prevent odorous emissions from the facility from
causing or contributing to objectionable odors beyond the facility's boundary. No objectionable odors were detected during the
compliance inspection. No odorous emissions testing/monitoring/record keeping/reporting is required by the facility's air
permit.
(8) 15A NCAC 2Q.0317:PREVENTION OF SIGNIFICANT DETERIORATION(PSD)AVOIDANCE CONDITIONS—The
following emission sources are subject to the 2D.0530 avoidance condition: The three brick kilns (ID Nos.K-1, K-2, &K-3).
IN COMPLIANCE--To avoid applicability of 15A NCAC 2D .0530, sulfur dioxide(S02) emissions from the facility must not
exceed 250 tons per consecutive 12-month period each. The permit requires the facility to monitor the amount of natural gas
and fuel oil combusted in the three kilns, keep monthly records of fuel combustion and S02 calculations, and submit quarterly
reports demonstrating compliance with the S02 emission limit. All recent quarterly reports from this facility have been
sublllltted on time allu llave uernonstrateu compliance with the PSOD avoidance limit.
(9) 15A NCAC 2Q.0317: MAXIMUMACHEIVABLE CONTROL TECHNOLOGY(MALT)AVOIDANCE CONDITIONS—The
following emission sources are subject to the 2D.1111 avoidance condition: The three brick kilns (ID Nos.K-1. K-2. &K-3).
IN COMPLIANCE—To avoid the applicability of 15A NCAC 21) .1111 and remain classified a minor source for hazardous air
pollutants(HAPs), facility-wide emissions of any individual HAP must be less than 10 tons per year and all HAPs combined
must be less than 25 tons per year. The facility reported in their second semi-annual report for 2018 that the greatest individual
HAP was hydrogen fluoride with an emission for the last six months of 2018 of 1,266 pounds. The total for all HAPs for the
same period was reported at 2,838 pounds. This permit condition became effective on January 23, 2018 with the issuance of
revision T11. Compliance is expected.
(VI)EXEMPT EMISSION SOURCES: The facility currently has several emission sources listed on the Insignificant
Activities List attached to the current air permit. No additional emission sources were observed during the inspection that would
need to be added to the Insignificant Activities List, and no concerns were noted with regard to the operation or permit
exemption status of the current sources on the list.

(VH) COMPLIANCE HISTORY: The facility was issued a Notice of Deficiency(NOD) on May 31, 2017 for late quarterly
reporting. On May 12, 2017 a Notice of Violation(NOV)was issued for a failed stack test of Kiln 3 which was originally tested
on September 12, 2016. On April 3, 2008 the facility was issued a Notice of Violation/Notice of Recommendation for
Enforcement(NOV/NRE)and was fined$2,190 for the associated report violation. On June 6, 2007, a Notice of Violation
(NOV)was issued regarding incomplete reporting for the 2"d half of 2006. Prior to that an NOV was issued on March 30, 2004
for incomplete reporting in your 2003 annual compliance certification. Prior to that an NOV was issued on December 15, 2003
for failure to submit a semiannual report for the first half of 2003 by the July 30,2003 due date.
(VIII)EMISSIONS INVENTORY REVIEW: Kiln 3 was the only kiln that operated in 2017 and the production was 2.35
percent less than the production in 2016 and for the first time in several years, the facility operated the Kiln 3 control device, a
DLA,the entire time without bypassing it during the year. Facility did not account for the condensible portion of particulate
matter(PM)for Kiln 3 DLA and so this was corrected to include both filterable and condensible particulate matter. The benefit
of the DLA is more suited for the control of BF and HCL than it is for PM. This would explain the much lower emission of HF
and HCL in 2017 vs the other years when they were operating in an uncontrolled condition with much higher emissions of HF
and HCL. The facility made no distinction between TSP,PM-10,and PM-2.5 emissions so all three will have the same value
for 2017. In the past we had given them credit for PM-10 being less than TSP and PM-2.5 being less than PM-10. The review
of their 2018 emissions inventory had not been completed and approved at the time of this inspection,but similar results to the
2017 inventory is expected.
(IX) STACK TEST REVIEW: The most recent stack test at this facility was a"retest"performed on February 9, 2017,on
Kiln 3 to demonstrate compliance with 2D .1109 Case by Case MACT. Prior to that, on September 12, 2016 the initial
performance test for Kiln 3 to show compliance with 2D .1109 Case by Case MACT was conducted but the test results indicated
an exceedance of the particulate limit and thus the need to retest.
(X)CONCLUSIONS/RECOMMENDATIONS: At the time of this inspection,Triangle Brick Company-Merry Oaks
appears to be in compliance with the terms and conditions of air quality permit number 06897T12. It is recommended that this
facility be inspected again in 2020.