AQ_F_1900009_20190206_CMPL_InspRpt (4)

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NORTH CAROLINA DIVISION OF Raleigh Regional Office
AIR QUALITY General Shale Brick,Inc. -Moncure Facility
NC Facility ID 1900009
Inspection Report County/FIPS: Chatham/037
Date: 02/08/2019
Facility Data Permit Data
General Shale Brick,Inc.-Moncure Facility Permit 04384/T39
300 Brick Plant Road Issued 1/13/2017
Moncure,NC 27559 Expires 12/31/2021
Lat: 35d 34.3530m Long: 79d 2.0830m Class/Status Title V
SIC: 3251 /Brick And Structural Clay Tile Permit Status Active
NAILS: 327121 /Brick and Structural Clay Tile Manufacturing Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP/Title V
J.Warren Paschal Kevin Ham J.Warren Paschal MACT Part 63: Subpart Brick-112jNSPS: Subpart 000
Manager of VP Engineering& Manager of
Environmental Research Environmental
Compliance [phone] Compliance
[phone] 1 [phone]
Compliance Data
omments: Facility appears to be compliant.
Inspection Date 02/06/2019
Inspector's Name Stanley Williams
Inspector's Signature: "��CV� Operating Status Operating
Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: 2 91 On-Site Inspection Result Compliance
Total Actual emissions in TO
TSP S02 NOX VOC CO PM10 *HAP
2017 66.78 0.8300 32.39 4.57 82.42 64.42 4349.70
2016 54.10 0.6800 26.61 3.88 67.68 52.85 3561.75
2015 60.72 0.7600 29.59 4.24 75.31 58.85 3474.60
*Highest HAP Emitted(in pounds)
Five Year Violation History:None
Date Letter Tyne Rule Violated Violation Resolution Date
Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested
(I)DIRECTIONS: General Shale Brick's Moncure Facility(General Shale) is located off Corinth Road in Moncure, Chatham
County. From Raleigh,take the beltline to US-1 South. Follow US-1 South for 17 miles to the exit for Old US 1 South. Turn
right off the exit ramp onto SR 1011. Travel approximately 4 miles and take a left onto Corinth Road(SR 1923). The facility
is approximately 4 miles down Corinth Road on the right.

(II)FACILITY DESCRIPTION: General Shale produces various sizes and styles of bricks at their Moncure facility. Clay is
transported to the plant from nearby mines,processed to a fine texture,and then extruded into bricks. The bricks then are
texturized prior to entering one of the brick kilns.
There are four brick kilns at the Moncure facility,two of which are older wood-fired kilns(Kilns 1 and 2)and two of which are
newer kilns(Kilns 3 and 4). Kilns 4 was converted from coal to natural gas in 2015 and Kiln 3 is currently not operational since
all the coal fuel system has been removed. The plans are to convert Kiln 3 to natural gas as their primary fuel just like Kiln 4,
but the conversion has not been done as of March 2017. All the kilns have four distinct zones: the drying zone, the preheating
zone,the firing zone, and the cooling zone. After exiting the kilns,the bricks are packaged for shipping. Standard personal
protective equipment for this facility would include,bu not limited to,hard hat, safety glasses, hearing protection, and safety
shoes.
Note: Kilns 1 and 2 are also referred to as the Cape Fear plant or Plant#24, and Kiln 3 and 4 are referred to as the Brickhaven
plant or Plant#25.
(III)INSPECTION SUMMARY: On February 6,2019,I(Stan Williams)met with Mr.Warren Paschal,Manager of
Environmental Compliance for General Shale, for the purpose of conducting an air quality permit compliance inspection. We
began with a review of revision 39 of their permit,looking at all the monitoring and recordkeeping requirements of the permit.
All records were complete and up to date. Mr.Paschal also indicated that the conversion of Kiln 3 from coal to natural gas has
not occurred yet and the unit remains idle with all coal fuel having been removed from the facility. This was also the case at the
time of last year's compliance inspection. Following our discussions,Mr. Paschal and I toured the facility. At the time of my
inspection,the only brick tunnel kiln operating was Kiln 4 and it appeared to be operating well from an air quality standpoint
with opacity of zero percent from the DLA stack. It was operating on a 31-car per day schedule. Comments about observations
made during the inspection are provided below for each of the emission sources and specific conditions listed in the facility's
current air permit.
(IV)PERMITTED EMISSION SOURCES: At the time of the inspection,General Shale's Moncure Plant was operating
under Air Permit No. 04384T39,which was issued on January 13,2017,expires on December 31, 2021, and includes the
following emission sources and control devices:
A. Brick tunnel kilns 1, 2, 3, and 4 and associated dryers consisting of
Two wood/natural gas-fired brick tunnel kilns (27 million Btu per hour maximum heat input rate
and 13.7 tons per hour maximum fired brickproduction rate, each, ID Nos. ES-KI and ES-K2)
and associated sawdust rotary dryer(ID No. ES-WD1,2);
One coal/natural gas/propane fired brick tunnel kiln (25.9 million Btu per hour maximum heat
input rate and 20.55 tons per hour maximum fired brick production rate, ID No. ES-K3K)and
associated dry limestone adsorber(ID No. CD-K3DLA)and the three associated natural
gas/propane-fired brick dryers (ID Nos. ES-K3D1, ES-K3D2, and ES-K3D3); and
One coal/natural gas/propane-fired brick tunnel kiln (25.9 million Btu per hour maximum heat
input rate and 20.55 tons per hour maximum fired brick production rate, ID No. ES K4K) and
associated dry lime injection fabric filter(ID No. CD-K4DIFF)and the three associated natural
gas/propane-fired brick dryers (ID Nos. ES-K4D1, ES-K4D2, and E4-K3D3);
Kiln ES-K4K was the only kiln in operation at the time of my inspection and it was firing natural gas. I did not
observe any visible emissions (VE)from the DLA stack and no VE from the dryer stacks. At the time of my
inspection the kiln was operating on a 31-car per day schedule.
B. One wood fuel/sawdust system consisting of two 8 x 8 screen, cyclone, hammermill, sawdust silo,
surge hopper, transfer screw conveyor, screen feed conveyor, and enclosed conveyor(ID Nos. ES-
WFS-SD-SCI, ES-WFS-SC2, ES-WFS-SD-CYC, ES-WFS-SD-HM, ES-WFS-SD-SDS, ES-WFS-SD-

SH, ES-WFS-SD-CVI, ES WFS--CV2, and ES-WFS-SD-CV3)controlled by two dust collectors, one
cyclone, and two bin ventfilters (ID Nos. CD-SD-DCI, CD-SD-DC2, ES-WFS SD-CYC, CD-SD-
BVI, and CD-SD-BV2);
This equipment was not operating at the time of my inspection.
C. Natural gas-fired coatings rotary dryer(3.45 tons of coatings per hour maximum drying capacity,
250,000 Btu per hour firing rate,ID No. ES CD-8);
This equipment was not operating at the time of my inspection.
D. Two texturizing operations (ID Nos. ES-CR5 and ES-CR6) controlled by two bagfilters (6,096 and
3,040 square feet of filter area, respectively, ID Nos. CD-CR6BF and CD-CR6BF2), one
texturizing operation (ID No. ES-CR7) controlled by two bagfilters (6,096 and 4,062 square feet of
filter area respectively, ID Nos. CD-CR7BF and CD-CR7BF2), and sand silo system (ID No. ES-
SS) controlled by one bin ventfilter(ID No. CD-SS-BV3);
This equipment was not operating at the time of my inspection.
E. Clay crushing, grinding, and screening operations including one NSPS-affected primary crusher
(ID No. F-PC), two NSPS-affected scalping screens (ID Nos. F-SSI and F-SS2), one NSPS affected
hammermill (ID No. F-HM), two single deck finishing screens (ID Nos. F-FS1 and F-FS2), one
bank of seven finishing screens (ID Nos. F-FS3, F-FS4, F-FS5 through F-FS9), two NSPS-affected
finishing conveyors #4 and #5 (ID Nos. F-FC4 and F-FCS), and one NSPS-affected intersite
conveyor(ID No. F-C-CFBH);
This equipment was not operating at the time of my inspection.
F. One NSPS-affected grinding and screening operation (184 tons per hour maximum process rate)
consisting of
one impact crushers (ID No. F-CH-CI)
two scalping screens (ID Nos. F-CH-SSI and F-CH-SS2)
two hammermills (ID Nos. F-CH-HI and F-CH-H2)
four finishing screens (ID Nos. F-CH-FSI through F-CH-FS4)
seventeen conveyors (ID Nos. F-CH-FC, F-CH-SSFC, F-CH-Pl, F-CI-P2, F-CH-RC, F-CH-BC,
F-CH-CFC, F-CH-TI, F-CH-T2, F-CH-HFCl, F-CH-HFC2, F-CH-TCl, F-CH-TC2, F-CH-SFC-
1, F-CH SFC2, F-CH-SFC3, F-CH-SFC4);
This equipment has not yet been installed as reported in the previous inspection and that continues to be
the case at the time of this inspection.
G. One Concrete Block Plant consisting of one flyash silo (ID No. ES-BP-FAS) controlled by one bin
vent filter(227 square feet of filter area, ID No. CD-BP-BVI), one cement silo (ID No. ES-BP-CS)
controlled by one bin vent filter (227 square feet of filter area, ID No. ES-BP-BV2) and one batch
mixer (ID No. ES-BP-BM) controlled by one bagfilter (535 square feet of filter area, ID No. CD-
BP-BHI); and
This equipment was not operating at the time of my inspection.

H. One coal processing system one coal crusher(ID No. ES-Coal-CC) controlled by one bagfilter(ID
No. CD-Coal-CC)
This equipment was not operating at the time of my inspection.
(V) SPECIFIC PERMIT CONDITIONS: As is the case with all Title V permits, Air Quality Permit No. 4384T39 lists all of
the air quality regulations that apply to each of the permitted emission sources. To avoid redundancy in this report, the
applicable air quality regulations are discussed individually, and all of the permitted emission sources that are subject to a
specific regulation are noted.
(1) 1 SA NCAC 2D.0515:PARTICULATE FROM MISCELLANEOUS IND USTRIAL PROCESSES-Permit Items A, B, C, D, G,
and H are subject to 2D.0515.
IN COMPLIANCE-The particulate emission limit for each of the subject emission sources is determined based on the
individual process weight rates for the sources. No particulate emission testing is required by the facility's air permit. To
ensure compliance with the particulate emission limit,the facility is required to conduct monthly and annual inspections on all
control devices and semiannual inspections on the brick kilns. The facility is required to keep records of all inspection and
maintenance activities and submit a summary report every six months documenting any compliance exceptions. The inspection
and maintenance records appeared to be adequate. The six-month summary reports for 2018 were submitted on time.
(2) 15A NCAC 2D.0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES-Permit Items A and
C are subject to 2D.0516.
IN COMPLIANCE-The sulfur dioxide emission limit for each of these sources is 2.3 pounds per million Btu heat input. No
testing is required by the facility's air permit. No monitoring/record keeping/reporting is required for the combustion of wood,
natural gas, and propane in the combustion equipment. For coal combustion in Kilns 3 and 4,when operating under the
Alternative Operating Scenario(AOS),the sulfur content of all coal burned in the kilns must be less than 1.0 percent by weight.
To ensure compliance with this limit,the facility is required to monitor the sulfur content of all coal received at the facility,
maintain a logbook showing all coal received is below 1 percent by weight sulfur,and submit a summary report every six
months documenting any compliance exceptions. At the time of this inspection,as was the case at last year's inspection,there is
no coal at the facility and they continue to operate using natural gas only.
(3) 15A NCAC 2D. 0521: CONTROL OF VISIBLE EMISSIONS-Permit Items A, B, C, D, E, and H are subject to 2D.0521.
IN COMPLIANCE - T he visib-1-g-mm_irg_�-an the-Kilns 1 and 2 (ID No ES-K I and ES-K2) the sawdust dryer(ID No.
WD1,2),the coatings dryer(11)No. ES-CD), and two of the texturing operations(ID Nos.ES-CD5 and ES-CDo) is 40 percent
opacity. The visible emission limit for all other emission sources is 20 percent opacity. During the inspection,all of the
emission sources observed in operation were well below their respective 2D .0521 visible emissions standard.
No visible emission testing/monitoring/record keeping/reporting is required for any of emission sources other than those that
burn coal or process coal. For coal combustion sources operating under the AOS,the facility is required to monitor the visible
emissions once per week. The facility is required to maintain a logbook documenting all visible emissions observations and
submit a summary report every six months documenting any compliance exceptions. Upon request,plant personnel were able to
provide me with records of visible emission observations. The six-month summary reports for 2018 were submitted on time.
(4) 15A NCAC 2D.0524:NEW SOURCE PERFORMANCE STANDARDS(40 CFR 60, Subpart 000)-Permit Items E and F
are subject to NSPS Subpart 000.
IN COMPLIANCE-To comply with the requirements of Subpart 000,the facility must maintain particulate and visible
emissions below the source specific limits defined in the permit. The permit requires the facility to conduct monthly visible
observations on all NSPS-affected equipment. The facility must also record the results of the monthly observations in a logbook
and submit a summary report of all visible emission observations on a semiannual basis. Upon request,plant personnel were

able to provide me with records of monthly visible emission observations. The six-month summary reports for 2018 were
submitted on time.
It should be noted that the facility's permit outlines some additional NSPS notification,testing,monitoring,record keeping, and
reporting for the yet to be installed Kiln 4 grinding and screening operation(Permit Item F). According to Mr.Paschal,the
facility is prepared to meet all NSPS requirements for these emission sources once construction has commenced.
(5) 1 SA NCAC 2D.I100 and 2Q Q.0711: TOXIC AIR POLL UTANT REQUIREMENTS -All of the permitted emission sources
are subject to 2D.1100 and 2Q.0711.
IN COMPLIANCE-In conjunction with a prior permit application, the permittee submitted air modeling results that
demonstrated that emissions of the Toxic Air Pollutants (TAPS) listed in the permit were below state Ambient Air Standards
(AALs)beyond the fence line of the facility. To comply with 2D .1100,the permittee must maintain operational records to
ensure that the operational restrictions outlined in the permit are met. These restrictions are 54,800 pounds of brick per hour for
Kilns 1 and 2 and 82,200 pounds of brick per hour for Kilns 3 and 4. During the calendar year 2018,the highest production rate
for Kilns 1&2 and Kilns 3&4 was 0.0 pounds of brick per hour and 39,192 pounds of brick per hour,respectively. The facility
is required to submit quarterly reports demonstrating compliance with the operational restrictions. All recent quarterly reports
have been submitted on time and have demonstrated compliance with the toxics operational limits.
To comply with 2Q .0711,the Permittee must ensure that emissions of specified TAPs do not exceed the Toxic Permit Emission
Rates(TPERs) specified in the permit. If any of the TPERs are exceeded, the facility must obtain a permit to emit TAPS and
demonstrate compliance with state AALs.
(6) 1 SA NCAC 2D.1109: CAA§1126F); Case-by-Case MA CT FOR BRICK MANUFACTURERS—The following equipment is
subject to 2D.1109: The large brick tunnel kilns 3&4 (ID Nos. ES-K3K and K4K) and the smaller brick tunnel kilnsl&2 (ID
Nos. ES-KI and Ks).
IN COMPLIANCE—The initial compliance date for the emissions standards,work practice standards, and associated
monitoring,recordkeeping, and reporting requirements was July 29,2015. The conversion of Kiln 4 from coal to natural gas
was completed in approximately three(3)months and initial performance testing was completed on September 24,2015. The
conversion of Kiln 3 from coal to natural gas will take place later and the kiln remains"out of service". All the coal that was at
the facility has been transported to one of their sister facilities.
(7) 1 SA NCAC 2D.1806: CONTROL AND PROHIBITION OF ODOROUS EMISSIONS—All of the permitted emission sources
are subject to 2D.1806.
IN COMPLIANCE-To comply with 2D .1806,the Permittee shall not operate the facility without implementing management
practices or installing and operating odor control equipment sufficient to prevent odorous emissions from the facility from
causing or contributing to objectionable odors beyond the facility's boundary. No objectionable odors were detected during the
compliance inspection. No odorous emissions testing/monitoring/record keeping/reporting is required by the facility's air
permit.
(VI)EXEMPT EMISSION SOURCES: The facility currently has several emission sources listed on the facility's insignificant
activities attachment to the permit. No concerns were noted during the inspection with regard to these sources. Additionally, no
additional exempt emission sources were observed that would need inclusion on the permit's insignificant activities list.
(VII) COMPLIANCE HISTORY: According to the RRO compliance databases, General Shale's Moncure facility has
received four prior Notice of Violations (NOV)in the last eleven years. On July 26, 2006, an NOV/NRE was issued to the
facility for not maintaining the required pressure drop across the dry limestone adsorber(DLA) (ID No. CD-K4DLA. On
December 21,2006, an NOV was issued to the facility for several missed recordings of the daily limestone feeder setting for the
same dry limestone adsorber. On March 7,2008, a Notice of Continuing Violation was issued to the facility for combusting
coal in the Kiln ES-K4K without using the required dry lime injected fabric filter(CD-K4DIFF). The facility received a civil
penalty assessment of$5473.00 on December 3,2008. On March 25, 2009, an NOV was issued for a late semiannual report.

(VHI)EMISSIONS INVENTORY REVIEW: Brick production for 2017 was up 22.1 percent from the brick production in
2016 and that accounts for the vast majority of percent change for the pollutants emitted in 2017. The percent change in
Hexane,n-is due to the rotary sand dryer operation where the less than 0.2 pounds of emission in 2017 compared to the less
than 0.5 pounds of emission in 2016 for a pollutant that has a deminimus value of 100 pounds. Styrene,toluene,
dibutylphthalate,and hexane,n-were all below the deminimus levels and did not have to be reported although the facility did
report those emissions.
(IX) STACK TEST HISTORY: According to the IBEAM database,the most recent stack test performed at this facility was
performed on September 24, 2015. Prior to that, a stack test was performed in February of 2006. Both tests involved brick
tunnel kiln 4(ES-K4K0).
(X) CONCLUSIONS/RECOMMENDATIONS: Based on this inspection, General Shale's Moncure facility appears to be in
compliance with all applicable requirements. It is also recommended that this facility be re-inspected in one year.