COMMONWEALTH OF VIRGINIA

Department of Environmental Quality 

Piedmont Regional Office

STATEMENT OF LEGAL AND FACTUAL BASIS

Brick and Tile Corporation of Lawrenceville 

Plants 3 and 4 

16024 Governor Harrison Parkway

Lawrenceville, Virginia  23868 

Permit No. PRO­30872 

Title V of the 1990 Clean Air Act Amendments required each state to develop a permit program to ensure

that certain facilities have federal Air Pollution Operating Permits, called Title V Operating Permits. As

required by 40 CFR Part 70 and 9 VAC 5 Chapter 80, Brick and Tile Corporation of Lawrenceville has

applied for the reissuance of its Title V Operating Permit for the 16024 Governor Harrison Parkway facility

(Plants 3 and 4). The Department has reviewed the application and has prepared a draft Title V Operating

Permit.

Engineer/Permit Contact: Date:

Air Permit Manager: Date:

Deputy Director: Date:
Brick and Tile Corporation of Lawrenceville 

Plants 3 and 4 

PRO­30872 

Statement of Basis

Page 2

FACILITY INFORMATION

Permittee

Brick and Tile Corporation of Lawrenceville 

P.O. Box 45

Lawrenceville, VA 23868 

Facility

Brick and Tile Corporation of Lawrenceville 

Plants 3 and 4 

16024 Governor Harrison Parkway

Lawrenceville, VA 23868 

Facility ID No. 51­025­0027

SOURCE DESCRIPTION

NAICS Code: 327121– Manufacturer of face brick, pavers, and various brick shapes.

This facility consists of two operating brick plants, Plants 3 and 4.  Brick manufacturing consists of mining, which is done at other areas in the locality, followed by grinding, blending of raw materials, extrusion, cutting

or shaping, drying, firing, packaging and shipping of the final product.

The facility is a Title V major source of PM 10, CO, HF, and HCl. This source is located in an attainment

area for all pollutants, and is not subject to PSD. The facility has a minor NSR construction permit dated

August 16, 2004.

COMPLIANCE STATUS

A full compliance evaluation of this facility, including a site visit, has been conducted on 8/18/2005.  In 

addition, all reports and other data required by permit conditions or regulations, which are submitted to 

DEQ, are evaluated for compliance.  Based on these compliance evaluations, the facility has not been

found to be in violation of any state or federal applicable requirements at this time
Brick and Tile Corporation of Lawrenceville 

Plants 3 and 4 

PRO­30872 

Statement of Basis

Page 3

EMISSION UNIT AND CONTROL DEVICE IDENTIFICATION

The emissions units at this facility consist of the following equipment:

Emission Unit Description Pollution  Control Device Description Stack ID 

Emission Unit ID 

Size/Rated 

Capacity

PCD ID 

Pollutant 

Controlled 

Applicable Permit Date

Brick Plant #3

Plant #3 Truck Dumping and Crushing Equipment

Truck Dump Feeder Bin ES­3­TD  50 yd

3  8/16/2004

Feeder from ES­3­TD to ES­3­C1 

ES­3­F1 36” wide 8/16/2004

Feeder to crusher  ES­3­F2 36” wide 8/16/2004

Feeder fed by front end loader from crushed storage ES­3­F3 36” wide 8/16/2004

Feeder fed by front end loader from crushed storage ES­3­F4 36” wide 8/16/2004

Feeder fed by front end loader from crushed storage ES­3­F6 36” wide 8/16/2004

Conveyor from ES­3­F1 to ES­3­CR1 w/ 1 drop point 

ES­3­C1  48” wide 8/16/2004

McClanahan Roll Crusher  ES­3­CR1

300 tons/hr  Full Enclosure PM/PM10  8/16/2004

NSPS OOO

Conveyor from ES­3­CR1 to ES­3­C2 w/1 drop point 

ES­3­C1A  36” wide

8/16/2004

NSPS OOO

fugitive

Conveyor from C1A to crushed material storage w/1

drop point 

ES­3­C2 

36” wide

8/16/2004

NSPS OOO
Brick and Tile Corporation of Lawrenceville 

Plants 3 and 4 

PRO­30872 

Statement of Basis

Page 4

Emission Unit Description Pollution  Control Device Description Stack ID 

Emission Unit ID 

Size/Rated 

Capacity

PCD ID 

Pollutant 

Controlled 

Applicable Permit Date

Plant #3, Grinding Room Equipment

Conveyor from ES­3­F3, ES­3­F4 & ES­3­F6 to

scalping screen w/1 drop point ??

ES­3­C3 

30” wide

8/16/2004

NSPS OOO

Simplicity Scalping Screen ES­3­SS1 5’ x 14’ 8/16/2004

NSPS OOO

Conveyor from scalping and finishing screens to

feeder 5 w/ 1 drop point 

ES­3­C4 

30” wide

8/16/2004

NSPS OOO

Feeder to Hammermill

ES­3­F5 36” wide

8/16/2004

NSPS OOO

J.C. Steele Hammermill

ES­3­HM 275 tons/hr  8/16/2004NSPS OOO

Conveyor from hammermill to C7 w/1 drop point 

ES­3­C6  36” wide

8/16/2004

NSPS OOO

Conveyor from C6 to C8 w/1 drop point 

ES­3­C7  30” wide

8/16/2004

NSPS OOO

Conveyor from C7 to finishing screens w/1 drop point 

ES­3­C8  30” wide

8/16/2004

NSPS OOO

Leahy Model F1 Finishing Screen ES­3­FS1 5’ x 8’ 8/16/2004

NSPS OOO

Leahy Model F1 Finishing Screen ES­3­FS2 5’ x 8’ 8/16/2004

NSPS OOO

Leahy Model F1 Finishing Screen ES­3­FS3 5’ x 8’ 8/16/2004

NSPS OOO

Leahy Model F1 Finishing Screen ES­3­FS4 5’ x 8’ 8/16/2004

NSPS OOO

Leahy Model F1 Finishing Screen ES­3­FS5 5’ x 8’ 8/16/2004

NSPS OOO

Leahy Model F1 Finishing Screen ES­3­FS6 5’ x 8’ 8/16/2004

NSPS OOO

Conveyor from finishing and scalping screens to C10 w/ 1 drop point 

ES­3­C9 

30” wide

8/16/2004

NSPS OOO

EP­3­GR­ 

BH 

Conveyor to C11 w/ 1 drop point 

ES­3­C10 30” wide

Mikro­Pulsaire Type 400S1­220

TRH Fabric filter  dust collection

system with a maximum air flow  capacity of 

33,600 ACFM

(ES­3­GR) 

PM/PM10

8/16/2004

NSPS OOO

Plant #3, Ground Material Storage (225 tons/hr capacity)

Front End loader  ES­3­FL 4.5 yd

3  10/21/2002

Conveyor from C10 to C12 or C13 w/2 drop points

ES­3­C11 30” wide

10/21/2002

NSPS OOO

Conveyor C11 to Brick Making Room w/1 drop point 

ES­3­C12 30” wide

10/21/2002

NSPS OOO

Fugitive

Reversible conveyor to storage w/1 drop point 

ES­3­C13 30” wide

10/21/2002

NSPS OOO
Brick and Tile Corporation of Lawrenceville 

Plants 3 and 4 

PRO­30872 

Statement of Basis

Page 5

Emission Unit Description Pollution  Control Device Description Stack ID 

Emission Unit ID 

Size/Rated 

Capacity

PCD ID 

Pollutant 

Controlled 

Applicable Permit Date

Plant #3, Brick Making Room (58 tons/hr green brick)

Coating Station ES­3­CS1 1240 lbs­  coatings/hr  10/21/2002

EP­3­MR­ 

BH  Coating Station ES­3­CS2 

1240 lbs­  coatings/hr 

Donaldson Company, Inc. 

fabric filter dust  collection system

w/maximum air 

flow of 17,000

ACFM

PM/PM10

10/21/2002

Plant #3, Brick Finishing Equipment

EP­3­BD 

Harrop Industries tunnel dryer with startup/backup

heat burning natural gas and propane backup

ES­3­BD 

9 x 10

6  btu/hr heat 

input 

14.8 tons

fired

brick/hr 

10/21/2002

EP­3­K 

Harrop Industries tunnel kiln with multigas burner 

(natural gas with propane backup) 

ES­3­K 

25 x 10

6  btu/hr total

heat input 

14.8 tons

fired

brick/hr 

10/21/2002

Plant #4 Truck Dumping and Crushing Equipment

Truck Dump Feeder Bin ES­4­TD  50 yds

3  8/16/2004

Feeder Bin for truck dumping

ES­4­F1 5’ x 22’ 8/16/2004

Feeder fed by front end loader from crushed storage ES­4­F2 400 ft 3  8/16/2004

Feeder fed by front end loader from crushed storage ES­4­F3 400 ft 3  8/16/2004

fugitive

Conveyor w/1 drop point 

ES­4­C1  48 “ wide

8/16/2004

NSPS OOO

Full Enclosure N/A  McLanahan 24 x 48 shalemaster twin Roll Crusher  ES­4­CR1

300 tons/hr  N/A PM/PM10  8/16/2004

NSPS OOO

Conveyor w/1 drop point 

ES­4­C2  48” wide

8/16/2004

NSPS OOO

Conveyor w/1 drop point 

ES­4­C3  48” wide

8/16/2004

NSPS OOO

Conveyor w/1 drop point 

ES­4­C5  40” wide

8/16/2004

NSPS OOO

fugitive

Reversing conveyor  ES­4­C6SR  40” wide8/16/2004

NSPS OOO
Brick and Tile Corporation of Lawrenceville 

Plants 3 and 4 

PRO­30872 

Statement of Basis

Page 6

Emission Unit Description Pollution  Control Device Description Stack ID 

Emission Unit ID 

Size/Rated 

Capacity

PCD ID 

Pollutant 

Controlled 

Applicable Permit Date

Plant #4, Grinding Room Equipment

JC Steele Hammer mill

ES­4­HM 275 tons/yr  8/16/2004NSPS OOO

Midwestern Scalping Screen ES­4­SS1

5’ x 7’ w/multiple

screen

decks

8/16/2004

NSPS OOO

Midwestern Finishing Screen ES­4­FS1

5’ x 7’ w/multiple

screen

decks

8/16/2004

NSPS OOO

Midwestern Finishing Screen ES­4­FS2

5’ x 7’ w/multiple

screen

decks

8/16/2004

NSPS OOO

Midwestern Finishing Screen ES­4­FS3

5’ x 7’ w/multiple

screen

decks

8/16/2004

NSPS OOO

Midwestern Finishing Screen ES­4­FS4

5’ x 7’ w/multiple

screen

decks

8/16/2004

NSPS OOO

Midwestern Finishing Screen ES­4­FS5

5’ x 7’ w/multiple

screen

decks

8/16/2004

NSPS OOO

Conveyor w/1 drop point 

ES­4­C7  32” wide

8/16/2004

NSPS OOO

Conveyor w/1 drop point 

ES­4­C8  28” wide

8/16/2004

NSPS OOO

Conveyor w/1 drop point 

ES­4­C9  40” wide

8/16/2004

NSPS OOO

Conveyor w/1 drop point 

ES­4­C11 36” wide

8/16/2004

NSPS OOO

Conveyor w/1 drop point 

ES­4­C12 40” wide

8/16/2004

NSPS OOO

Conveyor w/1 drop point 

ES­4­C13 40” wide

8/16/2004

NSPS OOO

Conveyor w/1 drop point 

ES­4­C15 32” wide

8/16/2004

NSPS OOO

EP­4­GR­ 

BH 

Reversing Conveyor w/1 drop point 

ES­4­C16AR  32” wide

Donaldson­Day

232RF10

Baghouse with a maximum air flow  capacity of 

26.730 ACFM

ES­4­GR 

PM/PM10

8/16/2004

NSPS OOO
Brick and Tile Corporation of Lawrenceville 

Plants 3 and 4 

PRO­30872 

Statement of Basis

Page 7

Emission Unit Description Pollution  Control Device Description Stack ID 

Emission Unit ID 

Size/Rated 

Capacity

PCD ID 

Pollutant 

Controlled 

Applicable Permit Date

Plant #4, Ground Material Storage

Reclaimer Chain Conveyor  ES­4­RC

85 tons material/hr225

tons/hr 

8/16/2004

Conveyor w/1 drop point 

ES­4­C16B  32” wide

8/16/2004

NSPS OOO

Conveyor w/1 drop point 

ES­4­C16C  32” wide

8/16/2004

NSPS OOO

Reversing conveyor w/ 2 drop points

ES­4­C18SR  32” wide

8/16/2004

NSPS OOO

Conveyor w/1 drop point 

ES­4­18W  32” wide

8/16/2004

NSPS OOO

Conveyor w/1 drop point 

ES­4­C18E  32” wide

8/16/2004

NSPS OOO

Fugitive

Conveyor w/1 drop point 

ES­4­C19 (head section)  32” wide

8/16/2004

Plant #4, Brick Making Room

Coating Station w/1 pickup point 

ES­4­CS1 

58 tons green

brick/hr  8/16/2004

Coating Station w/1 pickup point 

ES­4­CS2 

58 tons green

brick/hr  8/16/2004

Coating Station w/1 pickup point 

ES­4­CS3 

58 tons green

brick/hr  8/16/2004

Coating Station w/1 pickup point 

ES­4­CS4 

58 tons green

brick/hr  8/16/2004

Coating Station w/1 pickup point 

ES­4­CS5 

58 tons green

brick/hr  8/16/2004

Additive Feeder w/3 pickup points

ES­4­AF1

58 tons green

brick/hr  8/16/2004

Additive Feeder w/3 pickup points

ES­4­AF2

58 tons green

brick/hr  8/16/2004

Additive Feeder w/3 pickup points

ES­4­AF3

58 tons green

brick/hr  8/16/2004

Additive Feeder w/3 pickup points

ES­4­AF4

58 tons green

brick/hr  8/16/2004

Conveyor  ES­4­C19 (tail section)  32” wide 8/16/2004

Conveyor  ES­4­C20 32” wide 8/16/2004

Conveyor  ES­4­C21 32” wide 8/16/2004

Coating system with 30 pickup points

ES­4­CS 

58 tons green

brick/hr  8/16/2004

EP­4­MR­ 

BH 

Sand blast booth with 2 pickup points

ES­4­SB 

58 tons green

brick/hr 

Donaldson­Day

156F10

Baghouse with a maximum air flow  capacity of 

14,138 ACFM.  ES­4­MR 

PM/PM10

8/16/2004

EP­4­SS  Bag filling station with 1 pickup point 

ES­4­BFS 

58 tons green

brick/hr  8/16/2004

Sand Silo ES­4­SS  1000 ft 3  Bin vent filter  PM/PM10 8/16/2004
Brick and Tile Corporation of Lawrenceville 

Plants 3 and 4 

PRO­30872 

Statement of Basis

Page 8

Emission Unit Description Pollution  Control Device Description Stack ID 

Emission Unit ID 

Size/Rated 

Capacity

PCD ID 

Pollutant 

Controlled 

Applicable Permit Date

Plant #4, Brick Finishing Equipment

EP­4­BD1 

EP­4­BD2 

Ceric, Inc Twin Track Predryer and Dryer  equipped with a supplemental heater and using

natural gas and propane backup

ES­4­BD 

10 x 10

6 btu/hr  heat input 

14.8 tons fired

brick/hr 

8/16/2004

EP­4­  SCRB 

Ceric, Inc. Standard Sand Seal tunnel Kiln using

natural gas and propane backup

ES­4­K 

43.4 x 10

6 btu/hr 

total heat input 

14.8 tons fired

brick/hr 

Hellmich HKD­R

dry hydrated lime

injection

baghouse system

w/ maximum air 

flow of 40,000

ACFM and maximum lime

flow of 132 lbs/hr  ES­4­SCRB 

SO2  , HCl, HF, 

PM, PM10  8/16/2004

EP­4­LS  Lime Storage silo ES­4­LS 

36 tons lime

transported/hr  Bin vent filter  PM/PM10  8/16/2004

EMISSIONS INVENTORY

A copy of the 2003 annual emission update may be found in Attachment 1.  Emissions are summarized in 

the following table.

Pollutant Emission in Tons/Year

VOC CO  SO2  PM10  NOx HCL  HF 

3.02  84.33 39.76 93.92 25.03 8.93  40.88

EMISSION UNIT APPLICABLE REQUIREMENTS – Plant #3

Limitations

The following limitations are from the 8/16/2004 NSR permit:

· Emission Controls – Particulate emissions from the Plant #3 grinding plant shall be controlled by

building enclosure with a fabric filter dust collection system with a maximum air flow capacity of 33,600 

ACFM. The control device shall be provided with adequate access for inspection and shall be in 

operation when the grinding plant is operating.

(9 VAC 5­50­260, Condition 3 of 8/16/2004 NSR permit)
Brick and Tile Corporation of Lawrenceville 

Plants 3 and 4 

PRO­30872 

Statement of Basis

Page 9

· Emission Controls – Particulate emissions from the Plant #3 texturing and coating equipment shall be

controlled by a fabric filter dust collection system with a maximum air flow capacity of 18,029 ACFM. The control device shall be provided with adequate access for inspection and shall be in operation

when the texturing and coating equipment is operating.

(9 VAC 5­50­260, Condition 4 of 8/16/2004 NSR permit)

· Control Efficiency ­ The fabric filter dust collection system controlling the Plant #3 texturing and 

coating equipment shall maintain a control efficiency for particulate of no less than 99.0% percent, on a 

mass basis.

(9 VAC 5­50­260, Condition 5 of 8/16/2004 NSR permit)

· Fugitive Emission Controls – Fugitive particulate emissions from the receipt of raw materials, primary

crushing, and raw material storage for Plant #3 shall be controlled by respective building enclosures. Fugitive emissions from transferring raw materials between buildings shall be controlled by covered

conveyors.

(9 VAC 5­50­260, Condition 6 of 8/16/2004 NSR permit)

· Production ­ The production of fired brick from Plant #3 shall not exceed 110,000 tons per year, calculated monthly as the sum of each consecutive 12 month period.

(9 VAC 5­80­1180, Condition 21 of 8/16/2004 NSR permit)

· Fuel ­ The approved fuels for the Plant #3 tunnel dryer and tunnel kiln are liquefied petroleum gas

(LPG) and natural gas. A change in the fuel may require a permit to modify and operate.

(9 VAC 5­80­1100, Condition 22 of 8/16/2004 NSR permit)

· Emission Limits ­ Emissions from the operation of the Plant #3 tunnel kiln shall not exceed the limits

specified below:

Particulate Matter/PM­10 21.3 lbs/hr 79.2 tons/yr

Sulfur Dioxide 9.9 lbs/hr 36.9 tons/yr

Nitrogen Oxides 5.2 lbs/hr 19.3 tons/yr

(as NO2)

Carbon Monoxide 17.8 lbs/hr 66.0 tons/yr

Volatile Organic 0.4 lbs/hr 1.3 tons/yr

Compounds

Particulate emission limitations for this unit are based on information from both the filterable and

condensable portions of stack test data. 

(9 VAC 5­50­260, 9 VAC 5­60­320, Condition 25 of 8/16/2004 NSR permit)

· Emission Limits ­ Emissions from the operation of the Plant #3 tunnel dryer shall not exceed the limits

specified below:
Brick and Tile Corporation of Lawrenceville 

Plants 3 and 4 

PRO­30872 

Statement of Basis

Page 10 

Particulate Matter/PM­10 2.8 lbs/hr 10.3 tons/yr

Nitrogen Oxides(as NO2) 1.5 lbs/hr 5.4 tons/yr

Carbon Monoxide 4.6 lbs/hr 17.1 tons/yr

Volatile Organic 0.5 lbs/hr 1.7 tons/yr

Compounds

(9 VAC 5­50­260, Condition 26 of 8/16/2004 NSR permit)

· Emission Limits ­ Emissions from the Plant #3 fabric filter dust collection system controlling the

grinding room shall not exceed the limits specified below:

Particulate Matter/PM­10 0.02 grains/dscft 5.8 lbs/hr 8.6 tons/yr

(9 VAC 5­50­260, 9 VAC 5­50­410, Condition 27 of the 8/16/2004 NSR permit, 40 CFR 60.672 (a)(1))

· Emission Limits ­ Emissions from the Plant #3 fabric filter dust collection system controlling the

texturing and coating equipment shall not exceed the limits specified below:

Particulate Matter/PM­10 0.01 grains/dscft 1.6 lbs/hr 1.6 tons/yr

(9 VAC 5­50­260, Condition 28 of 8/16/2004 NSR permit)

· Plant #3 Combined Emission Limits ­ Total emissions from the Brick Plant #3 shall not exceed the

limits specified below:

Particulate Matter/PM­10 31.4 lbs/hr 99.7 tons/yr

Sulfur Dioxide 9.9 lbs/hr 36.9 tons/yr

Nitrogen Oxides(as NO2) 6.6 lbs/hr 24.6 tons/yr

Carbon Monoxide 22.4 lbs/hr 83.1 tons/yr

Volatile Organic 0.8 lbs/hr 3.0 tons/yr

Compounds

(9 VAC 5­50­260, VAC 5­60­320, Condition 29 of 8/16/2004 NSR permit)

· Visible Emission Limit ­ Visible emissions from the fabric filter dust collection system controlling the

Plant #3 texturing and coating equipment and the Plant #3 tunnel kiln exhaust stack shall not exceed 5 

percent opacity as determined by the EPA Method 9 (reference 40 CFR 60, Appendix A).

(9 VAC 5­50­80, 9 VAC 5­50­260, Condition 37 of the 8/16/2004 NSR permit)

· Visible Emission Limit – Visible emissions from the exhaust of the baghouse controlling the Plant #3

grinding room equipment (ES­3­GR) shall not exceed 7 percent opacity as determined by EPA

Reference Method 9 (reference 40 CFR 60, Appendix A.)

(9 VAC 5­50­80, 9 VAC 5­50­260, 9 VAC 5­50­410, Condition 38 of the 8/16/2004 NSR permit)
Brick and Tile Corporation of Lawrenceville 

Plants 3 and 4 

PRO­30872 

Statement of Basis

Page 11 

40 CFR 60 Subpart OOO

The following limitations originate from 40 CFR 60 Subpart OOO and are not specifically listed in the

8/16/2004 NSR permit:

Emission unit ID #  Emission unit

description

Limitation  Citation

ES­3­CR1  Roll Crusher 15% opacity 40 CFR 60.672(c)

ES­3­C1A  Conveyor 10% 40 CFR 60.672(b)

ES­3­C2  Conveyor 10% 40 CFR 60.672(b)

ES­3­SS1  Scalping screen  40 CFR 60.672(a)

ES­3­FS1 thru FS6  Finishing screens 40 CFR 60.672(a)

ES­3­C3 thru C10  Conveyor 40 CFR 60.672(a)

ES­3­HM  Hammer mill 

7% and 0.022 gr/dscft

These limits are covered

by the grinding room 

baghouse limits for ES­ 3­GR. 40 CFR 60.672(a)

ES­3­C11 Conveyor 10% opacity 40 CFR 60.672(b)

ES­3­C12 Conveyor 10% 40 CFR 60.672(b)

ES­3­C13 Conveyor 10% 40 CFR 60.672(b)

40 CFR Subpart JJJJJ

The following limitation originates from 40 CFR 63 Subpart JJJJJ. The Plant #3 at this facility would qualify

as an existing unit since construction commenced before July 22, 2002 (40 CFR 63.8390(h)). The facility

may operate Plant #3 as a small tunnel kiln, meaning that the capacity will be less than 10 tons/hour, defined in 40 CFR 63.8390(b). While the actual hourly capacity of this unit is larger than 10 tons/hr, the

standard allows the facility to take a federally enforceable limitation on annual production equivalent to 10 

tph of fired product. This limitation would ensure that Plant #3 is not subject to 40 CFR 63 Subpart JJJJJ. See 40 CFR 63.8390(d) for this allowance.  However, at this time, the facility is undecided as to how it will 

apply Subpart JJJJJ to Kiln #3.  If economics dictate otherwise, they may decide to install control 

equipment. Plant #3 must comply with the NESHAP no later than May 16, 2006. See 40 CFR 63.8395(b)

for this date.  Since it is currently undecided how Plant #3 will meet the NESHAP limitations, a general 

condition will be added to the TV permit requiring that Plant #3 be in compliance with all applicable portions

of the MACT standard by the compliance date.

· Commencing May 16, 2006, Plant #3 shall operate in compliance with all applicable standards and 

requirements listed in 40 CFR 63 Subpart JJJJJ – National Emission Standards for Hazardous Air

Pollutants for Brick and Structural Clay Products Manufacturing.

(9 VAC 5­60­100, 40 CFR 63.8390(b), 40 CFR 63.8390(d), 40 CFR 63.8395(b))

Monitoring and Record Keeping

The following conditions originate in the 8/16/2004 NSR permit:

· Monitoring Devices ­ The fabric filter dust collection system controlling the Plant #3 texturing and 

coating equipment shall be equipped with devices to continuously measure the differential pressure 

drop across the fabric filter. Each monitoring device shall be installed, maintained, calibrated and

operated in accordance with approved procedures which shall include, as a minimum, the
Brick and Tile Corporation of Lawrenceville 

Plants 3 and 4 

PRO­30872 

Statement of Basis

Page 12 

manufacturer's written requirements or recommendations. Each monitoring device shall be provided 

with adequate access for inspection and shall be in operation when the control device is operating.

(9 VAC 5­80­1180, 9 VAC 5­50­20 C, 9 VAC 5­50­260, Condition 16 of 8/16/2004 NSR permit)

· Monitoring Device Observation ­ The devices used to continuously measure the differential pressure 

drop across the fabric filter controlling the Plant #3 texturing and coating equipment shall be observed

by the permittee with a frequency of not less than once per day while the texturing and coating

equipment is operating. The permittee shall keep a log of the observations.

(9 VAC 5­50­50 H, Condition 17 of 8/16/2004 NSR permit)

40 CFR 63 Subpart JJJJJ

Monitoring and Record Keeping: Since the method of compliance with the MACT for Plant #3 is currently

unknown, the monitoring and record keeping requirements for Plant #3 are undetermined and therefore will 

not be specified in the TV permit.

Testing

The following requirements originate in the 8/16/2004 NSR permit:

· Stack Test ­ Performance tests shall be conducted for hydrogen fluoride from Plant #3 tunnel kiln to 

determine a conservative method for estimating hydrogen fluoride (HF) emissions. The tests shall be

performed and reported within three years of the initial issuance date of the September 6, 2002 permit.

If a new kiln is build adjacent to this brick plant, hydrogen fluoride test data from the new kiln may be

used in lieu of testing Plant #3 tunnel kiln as long as adequate mass balance data for the raw material 

as described in Condition 60 (of the 8/16/2004 NSR permit) also exists. Tests shall be conducted and 

reported and data reduced as set forth in 9 VAC 5­50­30 and 9 VAC 5­60­30, and the test methods and 

procedures contained in each applicable section or subpart listed in 9 VAC 5­50­410 and 9 VAC 5­60­ 70. The details of the tests are to be arranged with the Director, Piedmont Region. The permittee shall 

submit a test protocol at least 60 days prior to testing. The test protocol shall include a discussion of 

methodology for comparing mass balance data, gathered in accordance with Condition 60 (of the

8/16/2004 NSR permit), to testing data.  One copy of the test results shall be submitted to the Director, Piedmont Region within 60 days after test completion and shall conform to the test report format 

enclosed with this permit.

(9 VAC 5­50­30, 9 VAC 5­80­1200, Condition 48 of the 8/16/2004 NSR permit)

A table of test methods has been included in the permit if testing is performed. The Department and EPA

has authority to require testing not included in this permit if necessary to determine compliance with an 

emission limit or standard.

Reporting

Reporting requirements from the 8/16/2004 NSR permit are listed together with the initial and continuing

compliance stack test conditions above. 

40 CFR 63 Subpart JJJJJ

Reporting: Since the method of compliance with the MACT for Plant #3 is currently unknown, the reporting

requirements for Plant #3 are undetermined and therefore will not be specified in the TV permit. However,
Brick and Tile Corporation of Lawrenceville 

Plants 3 and 4 

PRO­30872 

Statement of Basis

Page 13 

a general applicability by reference condition (III.A.16) is in the Title V Permit which states that it shall 

operate in compliance with all applicable requirements. Obsolete Conditions

Brick and Tile has demonstrated that the following conditions to monitor Sulfer Dioxide and Hydrogen

Flouride concentration in the raw materials are no longer necessary because the SO2 and HF 

concentrations have leveled out. Furthermore, the MACT JJJJJ will require  testing every five years which 

will require knowing these concentrations in the raw material.

· Sulfur Dioxide Mass Balance Testing ­ Within 90 days of the issuance date of this permit, September

6, 2002, and every 90 days thereafter, the permittee shall sample raw material for sulfur content. After

performing four such tests, the permittee shall submit to the Director, Piedmont Region a summary of 

all test data and any conclusions concerning variability of sulfur content in the raw material drawn from 

the data.  If the data shows little variability of sulfur content in the raw material, and DEQ concurs, the

permittee may reduce the frequency of monitoring the sulfur content of the raw material to the initial 

use of material from a new or untested stockpile.  When material from a new or untested stockpile is

used in the brick making operation, the permittee shall sample within 30 days of initial use of the

material.

(9 VAC 5­50­30 G, Condition 59 of the 8/16/2004 NSR permit)

· Hydrogen Fluoride Mass Balance Testing ­ Commencing within 30 days of the initial issuance date 

of this permit, September 6, 2002, and every 30 days thereafter, the permittee shall sample dried brick

and fired brick for fluoride content. The permittee shall gather enough information during each test to 

perform a mass balance around the Plant #3 tunnel kiln.  Monthly testing shall continue until the

permittee performs a stack test at this facility for hydrogen fluoride emissions from the tunnel kiln as

required in Condition 48 of the 8/16/2004 NSR permit. Data from the monthly testing shall be included

in the hydrogen fluoride emissions testing report, and a comparison shall be made between hydrogen

fluoride emission rates predicted via mass balance techniques and tested hydrogen fluoride emission

rates. This information shall be included in the hydrogen fluoride emissions testing report and shall 

also be discussed in the protocol for any such test. Based on the results of these tests, this permit may

be reopened to include updated hydrogen fluoride parametric monitoring limitations.

(9 VAC 5­50­30 G, Condition 60 of the 8/16/2004 NSR permit)
Brick and Tile Corporation of Lawrenceville 

Plants 3 and 4 

PRO­30872 

Statement of Basis

Page 14

EMISSION UNIT APPLICABLE REQUIREMENTS – Plant #4

Limitations

The following limitations are from the 8/16/2004 NSR permit:

· Emission Controls – The Plant #4 tunnel kiln (ES­4­K) shall be equipped with a Hellmich HKD­R dry

hydrated lime injection baghouse system (ES­4­SCRB) with a maximum air flow capacity of 40,000 

ACFM and a maximum lime flow rate of 132 lbs/hr. The dry hydrated lime injection baghouse system 

(ES­4­SCRB) shall be provided with adequate access for inspection and shall be in operation when the

Plant #4 tunnel kiln (ES­4­K) is operating.

(9 VAC 5­50­260, Condition 7 of 8/16/2004 NSR permit)

· Control Efficiency – The dry hydrated lime injection baghouse system (ES­4­SCRB) shall 

demonstrate and maintain the following control efficiencies for the following pollutants:

Sulfur Dioxide (SO2 ) 30.0% 

Hydrogen Fluoride (HF)  90.0% 

(9 VAC 5­50­260, Condition 8 of 8/16/2004 NSR permit, 40 CFR 63 Subpart JJJJJ Table 1)

· Emission Controls – Particulate emissions from the Plant #4 grinding room equipment, as listed in 

Condition 2 of the 8/16/2004 NSR permit, shall be controlled by a Donaldson­Day 232RF10

baghouse(ES­4­GR) with a maximum air flow capacity of 26,730 ACFM. The baghouse (ES­4­GR)

shall be provided with adequate access for inspection and shall be in operation when the grinding room 

is operating.

(9 VAC 5­50­260, Condition 9 of 8/16/2004 NSR permit)

· Control Efficiency ­ The baghouse controlling particulate emissions from the Plant #4 grinding room 

equipment (ES­4­GR) shall maintain and demonstrate a control efficiency for particulate of no less than 

99.0 percent, on a mass basis.

(9 VAC 5­50­260, Condition 10 of 8/16/2004 NSR permit)

· Emission Controls – Particulate emissions from the Plant #4 brick making room equipment, as listed

in Condition 2 above, shall be controlled during dry coating operations by a Donaldson­Day 156F10 

baghouse (ES­4­MR) with a maximum air flow capacity of 14,138 ACFM. The baghouse (ES­4­MR)

shall be provided with adequate access for inspection and shall be in operation when the brick making

room equipment is running dry coating operations.

(9 VAC 5­50­260, Condition 11 of 8/16/2004 NSR permit)

· Control Efficiency ­ The baghouse controlling particulate emissions from the Plant #4 brick making

room equipment (ES­4­MR) shall maintain and demonstrate a control efficiency for particulate of no

less than 99.0 percent, on a mass basis.

(9 VAC 5­50­260, Condition 12 of 8/16/2004 NSR permit)

· Emission Controls – Particulate emissions from the Plant #4 lime silo (ES­4­LS) and the Plant #4

sand silo (ES­4­SS) shall each be controlled by a bin vent filter. Each bin vent filter shall be provided 

with adequate access for inspection and shall be in operation when the respective silo is operating.

(9 VAC 5­50­260, Condition 13 of 8/16/2004 NSR permit)
Brick and Tile Corporation of Lawrenceville 

Plants 3 and 4 

PRO­30872 

Statement of Basis

Page 15

· Emission Controls – Particulate emissions from Plant #4 twin roll crusher (ES­4­CR1) shall be

controlled by full enclosure. The twin roll crusher and enclosure shall be provided with adequate 

access for inspection. The twin roll crusher shall not be operated unless the full enclosure is secured

with all doors and windows closed. 

(9 VAC 5­50­260, Condition 14 of 8/16/2004 NSR permit)

· Production ­ The production of fired brick from Plant #4 shall not exceed 129,648 tons per year, calculated monthly as the sum of each consecutive 12 month period.

(9 VAC 5­80­1180, Condition 23 of 8/16/2004 NSR permit)

· Fuel ­ The approved fuels for the Plant #4 tunnel kiln (ES­4­K) and the Plant #4 predryer and dryer

(ES­4­BD) are natural gas and propane.  A change in the fuel may require a permit to modify and 

operate.

(9 VAC 5­80­1100, Condition 24 of 8/16/2004 NSR permit)

· Emission Limits – Fugitive emissions from the operation of the Plant #4 truck dumping and crushing

equipment, as listed in Condition 2 of the 8/16/2004 NSR permit, shall not exceed the limits specified

below:

Particulate Matter/PM10  3.8 lbs/hr 16.6 tons/yr

Exceedance of the operating limits shall be considered credible evidence of the exceedance of

emission limits. Compliance with these emission limits may be determined as stated in condition

numbers 14, 23, 40, and 41 of the 8/16/2004 NSR permit.

(9 VAC 5­50­260, 9 VAC 5­50­410, Condition 30 of the 10/21/02 NSR permit)

· Emission Limits ­ Emissions from the exhaust of the Torit DFO 3­24 baghouse controlling the Plant #4

grinding room equipment (ES­4­GR) shall not exceed the limits specified below:

Particulate Matter/PM10  0.022 grains/dscf  5.0 lbs/hr 22.1 tons/yr

(9 VAC 5­50­260, 9 VAC 5­50­410, Condition 31 of the 8/16/2004 NSR permit, 40 CFR 60.672(a)(1))

· Emission Limits – Fugitive emissions from the operation of the ground material storage equipment, as

listed in condition 2 of the 8/16/2004 permit, shall not exceed the limits specified below:

Particulate Matter/PM10  2.7 lbs/hr 11.8 tons/yr

Exceedance of the operating limits shall be considered credible evidence of the exceedance of

emission limits. Compliance with these emission limits may be determined as stated in condition

numbers 23 and 40 of the 8/16/2004 NSR permit

(9 VAC 5­50­260, 9 VAC 5­50­410, Condition 32 of the 8/16/2004 NSR permit)

· Emission Limits ­ Emissions from the exhaust of the Donaldson­Day 156F10 baghouse controlling the

Plant #4 brick making room equipment (ES­4­MR) shall not exceed the limits specified below:

Particulate Matter/PM10  0.01 grains/dscf  1.2 lbs/hr 5.3 tons/yr

(9 VAC 5­50­260, Condition 33 of the 8/16/2004 NSR permit)

· Emission Limits ­ Emissions from the exhaust of the Plant #4 predryer and dryer, ES­4­BD, shall not
Brick and Tile Corporation of Lawrenceville 

Plants 3 and 4 

PRO­30872 

Statement of Basis

Page 16 

exceed the limits specified below:

Particulate Matter 2.8 lbs/hr 12.1 tons/yr

PM10  2.8 lbs/hr 12.1 tons/yr

Nitrogen Oxides 1.5 lbs/hr 6.4 tons/yr

(as NO2)

Carbon Monoxide (CO) 4.6 lbs/hr 20.1 tons/yr

Volatile Organic 0.4 lbs/hr 1.9 tons/yr

Compounds

(9 VAC 5­50­260, Condition 34 of the 8/16/2004 NSR permit)

· Emission Limits ­ Emissions from the exhaust of the Plant #4 dry hydrated lime injection baghouse 

system (ES­4­SCRB) controlling the Plant #4 tunnel kiln (ES­4­K) shall not exceed the limits specified

below:

Particulate Matter 0.12 lbs/ton fired brick 1.8 lbs/hr 7.8 tons/yr

PM10  0.12 lbs/ton fired brick 1.8 lbs/hr 7.8 tons/yr

Sulfur Dioxide (SO2 ) 6.9 lbs/hr 30.4 tons/yr

Nitrogen Oxides 5.2 lbs/hr 22.7 tons/yr

(as NO2)

Carbon Monoxide (CO) 17.8 lbs/hr 77.8 tons/yr

Volatile Organic 0.4 lbs/hr 1.6 tons/yr

Compounds

Total Fluorides, excluding HF  0.7 lbs/hr 3.1 tons/yr

Hydrogen Fluoride (HF)  1.2 lbs/hr 5.1 tons/yr

Hydrogen Chloride (HCl) 0.056 lbs/ton fired brick 0.83 lbs/hr 3.6 tons/yr

Particulate emission limitations for this unit are based on information from only the filterable portion of 

stack test data. 

(9 VAC 5­50­260, 9 VAC 5­60­100, Condition 35 of the 8/16/2004 NSR permit, 40 CFR 63 Subpart

JJJJJ Table 1)

· Plant #4 Combined Emission Limits ­ Total emissions from Plant #4 shall not exceed the limits

specified below:

Particulate Matter/PM10  17.3 lbs/hr 75.7 tons/yr
Brick and Tile Corporation of Lawrenceville 

Plants 3 and 4 

PRO­30872 

Statement of Basis

Page 17 

Sulfur Dioxide 6.9 lbs/hr 30.4 tons/yr

Nitrogen Oxides 6.6 lbs/hr 29.0 tons/yr

(as NO2)

Carbon Monoxide 22.3 lbs/hr 97.9 tons/yr

Volatile Organic 0.8 lbs/hr 3.5 tons/yr

Compounds

These emissions are derived from the estimated overall emission contribution from operating limits. Exceedance of the operating limits shall be considered credible evidence of the exceedance of

emission limits. Compliance with these emission limits may be determined as stated in the various

conditions of this permit.

(9 VAC 5­50­260, Condition 36 of the 8/16/2004 NSR permit)

· Visible Emission Limit ­ Visible emissions from the exhaust of the baghouse controlling the Plant #4

grinding room equipment (ES­4­GR) shall not exceed 7 percent opacity as determined by EPA Method

9 (reference 40 CFR 60, Appendix A).

(9 VAC 5­50­80, 9 VAC 5­50­260, and 9 VAC 5­50­410, Condition 39 of the 8/16/2004 NSR permit, 40

CFR 50.672(a)(2))

· Visible Emission Limit ­ Visible emissions from the following equipment shall not exceed 10 percent

opacity as determined by EPA Method 9 (reference 40 CFR 60, Appendix A).

Emission Unit ID #  Equipment Description Rated Capacity

ES­4­C1  Conveyor with 1 drop point  48” wide

ES­4­C2  Conveyor with 1 drop point  48” wide

ES­4­C3  Conveyor with 1 drop point  48” wide

ES­4­C5  Conveyor with 1 drop point  40” wide

ES­4­C6SR  Reversing conveyor with 1 drop point  40” wide

ES­4­C16B Conveyor with 1 drop point  32” wide

ES­4­C16C Conveyor with 1 drop point  32” wide

ES­4­C19 Conveyor with 1 drop point  32” wide

ES­4­C18SR Reversing conveyor with 1 drop point  32” wide

ES­4­C18W  Conveyor with 1 drop point  32” wide

ES­4­C18E Conveyor with 1 drop point  32” wide

(9 VAC 5­50­80, 9 VAC 5­50­260, 9 VAC 5­50­410, Condition 40 of the 8/16/2004 NSR permit, 40 CFR

672(b))

· Visible Emission Limit ­ Visible emissions from the Plant #4 fully enclosed roll crusher, ES­4­CR1, 

shall not exceed 15 percent opacity as determined by EPA Method 9 (reference 40 CFR 60, Appendix

A).

(9 VAC 5­50­80, 9 VAC 5­50­260, 9 VAC 5­50­410, Condition 41 of the 8/16/2004 NSR permit, 40 CFR

60.672(c))

· Visible Emission Limit ­ Visible emissions from the Plant #4 lime storage silo ES­4­LS and the Plant

#4 sand storage silo ES­4­SS shall each not exceed 5 percent opacity as determined by EPA Method 9 

(reference 40 CFR 60, Appendix A).
Brick and Tile Corporation of Lawrenceville 

Plants 3 and 4 

PRO­30872 

Statement of Basis

Page 18 

(9 VAC 5­50­80, 9 VAC 5­50­260, Condition 42 of the 8/16/2004 NSR permit)

· Visible Emission Limit ­ Visible emissions from the exhaust of the baghouse controlling the Plant #4

brick making room equipment, ES­4­MR, shall not exceed 5 percent opacity as determined by EPA

Method 9 (reference 40 CFR 60, Appendix A).

(9 VAC 5­50­80, 9 VAC 5­50­260, Condition 43 of the 8/16/2004 NSR permit)

· Visible Emission Limit – There shall be no visible emissions from the exhaust of the dry hydrated lime 

injection baghouse controlling the Plant #4 tunnel kiln (ES­4­K) as determined by EPA Method 22

(reference 40 CFR 60, Appendix A).

(9 VAC 5­50­80, 9 VAC 5­50­260, Condition 44 of the 8/16/2004 NSR permit, 40 CFR 63 Subpart

JJJJJ, Table 2)

40 CFR Subpart JJJJJ

The following limitations originate from 40 CFR 63 Subpart JJJJJ. The Plant #4 at this facility qualifies

as a new, large tunnel kiln under this standard.

· Plant #4 kiln, ES­4­K, must meet the following emission limitations:

Limitations  Citation

0.057 lbs HF/ton of fired product or reduction of HF 

emissions by 90%

40 CFR 63 Subpart JJJJJ, Table 1, #2.a. 

40 CFR 63 Subpart JJJJJ, Table 4, #2.a. 

0.056 lbs HCl/ton of fired product or reduction of 

HCl emissions by 85%

40 CFR 63 Subpart JJJJJ, Table 1, #2.b. 

40 CFR 63 Subpart JJJJJ, Table 4, #2.b. 

0.12 lb PM/ton fired product 40 CFR 63 Subpart JJJJJ, Table 1, #2.c. 40 CFR 63 Subpart JJJJJ, Table 4, #2.c.

These limitations are also in the 8/16/2004 NSR permit.

· Plant #4 kiln, ES­4­K, and associated scrubber, ES­4­SCRB, must meet the following operating

limitations:

Limitations  Citation

Maintain no visible emissions from the baghouse 

stack ES­4­SCRB

40 CFR 63 Subpart JJJJJ, Table 2, #2.a. 

40 CFR 63 Subpart JJJJJ, Table 5, #2.i. Maintain free­flowing lime in the feed hopper or silo 

and to the scrubber at all times

40 CFR 63 Subpart JJJJJ, Table 2, #2.b. 

40 CFR 63 Subpart JJJJJ, Table 5, #2.ii 

Maintain the feeder setting at or above the level 

established during the performance test for

scrubber ES­4­SCRB

40 CFR 63 Subpart JJJJJ, Table 2, #2.c. 40 CFR 63.Subpart JJJJJ, Table 5, #2, ii

These requirements are also in the 8/16/2004 NSR permit.

· Must be in compliance with Subpart JJJJJ limitations at all times except during startup, shutdown, and 

malfunction.

(9 VAC 5­60­100, 40 CFR 63.8420(a))

· Must develop and implement a written startup, shutdown, and malfunction plan (SSMP).
Brick and Tile Corporation of Lawrenceville 

Plants 3 and 4 

PRO­30872 

Statement of Basis

Page 19 

(9 VAC 5­60­100, 40 CFR 63.8420(c))

· Must prepare and implement a written operations, maintenance, and monitoring (OM&M) plan.

(9 VAC 5­60­100, 40 CFR 63.8420(d))

· OM&M plan must be available for inspections upon request. Must contain the following:

fi Each process and air pollution control device (APCD) to be monitored;

fi The type of monitoring device that will be used; and

fi Operating parameters to be monitored. fi Monitoring schedule specifying the frequency that the parameter values will be determined and

recorded.

fi Limits for each parameter that represent continuous compliance with the emission limitations. Limits must be based on values of the monitored parameters recorded during performance tests. fi Procedures for the proper operation and routine and long­term maintenance of the APCD,

including maintenance and inspection schedules that are consistent with the manufacturer’s

recommendations. fi Performance and equipment specifications for the sample interface, the pollutant concentration, or

parametric signal analyzer, and the data collection and reduction system. fi Continuous monitoring system performance evaluation procedures and acceptance criteria.

fi Procedures for the proper operation and maintenance of monitoring equipment

fi Continuous monitoring system data quality assurance procedures.

fi Continuous monitoring system record keeping and reporting procedures.

fi Procedures for responding to operating parameter deviations, including: ß Procedures for determining the cause of the operating parameter deviation. ß Actions for correcting the deviation and returning the operating parameters to the allowable 

limits

ß Procedures for recording the times that the deviation began and ended and corrective actions

were initiated and completed.

fi Procedures for keeping records to document compliance. 

(9 VAC 5­60­100, 40 CFR 63.63.8425(b))

It should be noted that 40 CFR 63.8420(e) allows the facility to bypass the Hellmich scrubber (ES­4­SCRB)

for routine maintenance if certain conditions are met. One condition, 40 CFR 63.8420(e)(1) states that the

request for the routine control device maintenance exemption must be provided to the permitting authority

along with other information. 40 CFR 63.8480(f) states that the request must be submitted no later than 30 

days before the compliance date of the unit. The compliance date of the new kiln (ES­4­K) was the date 

upon which it started up, and this date has been reached.  Therefore, the provisions within the MACT for the

routine maintenance exemption will not be included in the TV permit. The standards of 9 VAC 5­20­180 

shall apply.

Additionally, the TV permit shall contain the Table 7 of 40 CFR 63 Subpart JJJJJ to delineate which parts of 

the general provisions of this chapter apply to Plant #4. Monitoring and Record Keeping

The following conditions originate in the 8/16/2004 NSR permit:

· Monitoring Devices ­ The baghouse controlling the Plant #4 brick making room (ES­4­MR) shall be
Brick and Tile Corporation of Lawrenceville 

Plants 3 and 4 

PRO­30872 

Statement of Basis

Page 20 

equipped with devices to continuously measure the differential pressure drop across the baghouse. 

The baghouse controlling the Plant #4 grinding room (ES­4­GR) shall also be equipped with devices to 

continuously measure the differential pressure drop across the baghouse.  Each monitoring device 

shall be installed, maintained, calibrated and operated in accordance with approved procedures which 

shall include, as a minimum, the manufacturer's written requirements or recommendations. Each 

monitoring device shall be provided with adequate access for inspection and shall be in operation when 

each control device is operating.

(9 VAC 5­80­1180, 9 VAC 5­50­20 C, 9 VAC 5­50­260, Condition 18 of 8/16/2004 NSR permit)

· Monitoring Device Observation ­ The monitoring devices used to continuously measure the

differential pressure across the baghouse controlling the Plant #4 brick making room (ES­4­MR) and 

the baghouse controlling the Plant #4 grinding room (ES­4­GR) shall each be observed by the

permittee with a frequency of not less than once per day that the equipment being controlled operates. The permittee shall keep logs of the observations from each of the devices used to continuously

measure the differential pressure across the baghouse controlling the brick making room (ES­4­MR)

and the baghouse controlling the grinding room (ES­4­GR).

(9 VAC 5­50­50 H, Condition 19 of 8/16/2004 NSR permit)

· Monitoring Observations – The permittee shall create and maintain the following observations,

records, and logs:

a.  The permittee shall observe the exhaust of the dry hydrated lime injection baghouse (ES­4­

SCRB) with a frequency of not less than once per operating day while the kiln is under

normal operating conditions. The stack must be observed at least 15 minutes and in 

accordance with Method 22 of Appendix A, 40 CFR 60. If no visible emissions are 

observed in 30 consecutive daily Method 22 tests, the permittee may decrease the

frequency of observations from daily to weekly. If any visible emissions are observed

during weekly tests, the permittee must promptly initiate and complete corrective actions. The frequency of observation shall revert back to daily until the permittee can demonstrate 

that no visible emissions are observed in 30 consecutive daily tests, at which point in time 

the frequency of observations may be reduced to weekly. The permittee shall keep logs of 

times, dates, and results of daily examinations.

b.  The permittee shall continuously monitor the flow of lime to the auger of the dry hydrated 

lime injection baghouse (ES­4­SCRB). The monitoring device shall be equipped with an 

alarm that shall sound whenever lime is not free flowing. The output from the monitor of 

the flow of lime to the auger shall be continuously recorded. 

c. Once per shift, the feeder setting of the lime feed system shall be recorded.  The feeder

setting shall be maintained at or above the level established during the most recent

performance test showing compliance with this permit. The permittee shall keep logs of 

the once­per­shift feeder setting observations.

(9 VAC 5­50­50 H, 9 VAC 5­60­100,Condition 20 of 8/16/2004 NSR permit, 40 CFR 63 Subpart JJJJJ, Table 5, #2, 40 CFR 63.8470(g))

40 CFR 63 Subpart JJJJJ

The following requirements for monitoring and record keeping are from the MACT:
Brick and Tile Corporation of Lawrenceville 

Plants 3 and 4 

PRO­30872 

Statement of Basis

Page 21

· The permittee shall install, operate, and maintain each continuous monitoring system (CMS) according

to the OM&M plan and shall meet the following requirements:

fi Conduct a performance evaluation of each CMS according to the OM&M plan;

fi The CMS must complete a minimum of one cycle of operation for each successive 15 minute 

period. To have a valid hour, the permittee must have at least 3 of 4 equally spaced data values or

at least 75 percent if more than 4 data values per hour are collected, not including startup, shutdown, malfunction, out of control periods, or periods of routine control device maintenance). fi The permittee shall determine and record the 3 hour block averages of all recorded readings, calculated after every 3 hours of operation as the average of the previous 3 operating hours. To 

calculate the average for each 3 hour average period, the permittee must have at least 75 percent

of the recorded readings for that period (not including startup, shutdown, malfunction, out of control 

periods, or periods of routine control device maintenance). fi The permittee shall record the results of each inspection, calibration and validation check. fi At all times, the permittee must maintain the monitoring equipment including, but not limited to, 

maintaining necessary parts for routine repairs of the monitoring equipment.

(9 VAC 5­60­100, 40 CFR 63.8450(a))

· For the lime feed rate measurement device, the permittee shall meet the following requirements:

fi Locate the measurement device in a position that provides a representative feed rate 

measurement;

fi At least semiannually, conduct a calibration check.

(9 VAC 5­60­100, 40 CFR 63.8450(f))

· Except for periods of monitor malfunctions, associated repairs, and required quality assurance or

control activities, the permittee shall monitor continuously or collect data at all required intervals at all 

times that the Plant #4 kiln, ES­4­K, is operating. This includes startup, shutdown, malfunction, and 

routine control device maintenance. 

(9 VAC 5­60­100, 40 CFR 63.8465(b))

· During periods of startup, shutdown, and malfunction, Plant #4 must be operated according to the

Startup, Shutdown, and Malfunction Plan (SSMP).

(9 VAC 5­60­100, 40 CFR 63.8470(d))

· Deviations that occur during a period of startup, shutdown, or malfunction are not violations if the

permittee demonstrates to the Director, Piedmont Regional Office’s satisfaction that the facility was

operating according to an SSMP and an OM&M plan. The Director, Piedmont Region shall determine

whether deviations that occur during a period of startup, shutdown, or malfunction are violations.

(9 VAC 5­60­100, 40 CFR 63.8470(e))

· The permittee shall monitor the visible emissions from the stack of the Hellmich scrubber ES­4­SCRB, as required below:

fi The permittee shall perform daily visible emission observations of the ES­4­SCRB stack according

to the procedures of Method 22 of 40 CFR 60, Appendix A. The observations must take place 

while the unit is operating under normal conditions. The duration of each Method 22 test shall be at 

least 15 minutes.

fi If visible emissions are observed during any daily test conducted using Method 22 of 40 CFR 60, Appendix A, the permittee must promptly initiate and complete corrective actions according to your

OM&M plan. If no visible emissions are observed in 30 consecutive daily Method 22 tests for the
Brick and Tile Corporation of Lawrenceville 

Plants 3 and 4 

PRO­30872 

Statement of Basis

Page 22 

ES­4­SCRB stack, the permittee may decrease the frequency of Method 22 testing from daily to 

weekly for that kiln stack. If visible emissions are observed during any weekly test, the permittee

must promptly initiate and complete corrective actions according to the OM&M plan, resume 

Method 22 tests of ES­4­SCRB on a daily basis, and maintain that schedule until no visible 

emissions are observed in 30 consecutive daily tests, at which time the permittee may again 

decrease the frequency of Method 22 testing to weekly. fi If visible emissions are observed during any test, the permittee must report these deviations.

(9 VAC 5­60­100, 40 CFR 63.8470(g), 40 CFR 63 Subpart JJJJJ, Table 5, #2.i)

This is also required by the 8/16/2004 NSR permit.

· The permittee shall verify that lime is free flowing to the scrubber ES­4­SCRB via a load cell, carrier

gas/lime flow indicator, carrier gas pressure drop measurement system or other system. The output of 

this system shall be recorded, and if lime is found to not be free flowing, promptly initiate and complete 

the corrective actions in the OM&M plan.

(9 VAC 5­60­100, 40 CFR 63 Subpart JJJJJ, Table 5, #2.ii)

This is also required by the 8/16/2004 NSR permit.

· The permittee shall record the feeder setting once during each shift of operation to verify that the feeder

setting is being maintained at or above the level established during the performance test.

(9 VAC 5­60­100, 40 CFR 63 Subpart JJJJ, Table 5, #2.ii)

This is also required by the 8/16/2004 NSR permit.

· The permittee shall keep the following records for Plant #4:

fi A copy of each notification and report submitted to comply with 40 CFR 63 Subpart JJJJJ, to 

include all documentation supporting any Initial Notification or Notification of Compliance Status

submitted;

fi The following records related to startup, shutdown, and malfunction: 63.6(e)(3)iii thru v

fi Records of performance tests as required by 63.10(b)(2)(viii);

fi For each deviation of an operating limit parameter value, the date, time , and duration of the

deviation, a brief explanation of the cause of the deviation, and the corrective action taken, and 

whether the deviation occurred during a period of startup, shutdown, or malfunction;

fi Records of production rates on a fired product basis;

This is also required by the 8/16/2004 NSR permit. fi Records of maintenance and inspections performed on the scrubber ES­4­SCRB. fi Current copies of the SSMP and the OM&M plan, including any revisions, with records documenting

performance.

fi These records must be kept for 5 years.

(9 VAC 5­60­100, 40 CFR 63.8490, 40 CFR 63.8495)

Testing

The initial performance tests for Plant #4 have been performed and are listed in the obsolete conditions

page under the facility wide conditions heading.

40 CFR 63 Subpart JJJJJ

The following testing requirements originate in 40 CFR 63 Subpart JJJJJ:

· Initial startup for Plant #4 shall mean the time at which the kiln ES­4­K first reaches a level of
Brick and Tile Corporation of Lawrenceville 

Plants 3 and 4 

PRO­30872 

Statement of Basis

Page 23 

production that is equal to 75 percent of the kiln design capacity or 12 months after the kiln begins

firing, whichever is earlier.

(9 VAC 5­60­100, 40 CFR 63.8515)

This condition is already noted in the 8/16/2004NSR permit.

· Revision of the inspection and maintenance procedures of the OM&M plan does not require new

performance tests.

(9 VAC 5­60­100, 40 CFR 63.8425(d))

· Revision of the operating limits in the OM&M plan requires a new performance test. The permittee

shall meet the following requirements:

fi Must submit a notification of the performance test to the Director, Piedmont Regional Office

fi After completion of the tests to demonstrate compliance with the emission limits can be achieved at 

the revised operating limit parameter value, the permittee shall submit the performance test results

and the revised operating limits as part of the Notification of Compliance Status.

(9 VAC 5­60­100, 40 CFR 63.8425(c), 40 CFR 63.8440(b))

· After the initial demonstration, performance tests shall be performed every 5 years.

(9 VAC 5­60­100, 40 CFR 63.8440 (a))

· Prior to performance testing, the permittee shall install and calibrate all monitoring equipment.

(9 VAC 5­60­100, 40 CFR 63.8440(b))

· Performance testing shall be conducted while operating at the maximum production level.

(9 VAC 5­60­100, 40 CFR 63.8445(d))

· Testing shall not be conducted during periods of startup, shutdown, or malfunction.

(9 VAC 5­60­100, 40 CFR 63.8445(e))

· Each test shall consist of 3 runs, and each run must last at least an hour.

(9 VAC 5­60­100, 40 CFR 63.8445(f))

· Must use data from tests and the following equations to determine compliance:

fi For production based emission limits, use  MP=ER/P where: 

MP =  Mass per unit of production, lbs of pollutant per ton of fired product

ER =  Mass emission rte of pollutant during each performance test lbs per hour

P =  Production rate during each performance test run, tons of fired product

per hour

fi For percent reduction emission limits, use PR=(ERi – ERo)/ERi  where: 

PR =  Percent reduction, percent

ERi =  mass emission rate of specific HAP entering ES­4­SCRB, lbs per hour

ERo =  mass emission rate of specific HAP exiting ES­4­SCRB, lbs per hour

(9 VAC 5­60­100, 40 CFR 63.8445(g))

· For Plant #4, the permittee must perform the following tests on the inlet and exhaust of the scrubber

ES­4­SCRB:
Brick and Tile Corporation of Lawrenceville 

Plants 3 and 4 

PRO­30872 

Statement of Basis

Page 24

Method  Determination  Citations

40 CFR 60 Appendix A, Methods

1 through 4 or alternative test

methods

Site locations, velocities,

volumetric flow rates, gas

molecular weight, and moisture 

content

40 CFR 63 Subpart JJJJJ Table 

3, #1 a through d 

40 CFR 60, Appendix A, Method

26 or 26A or 40 CFR 63, Appendix A, Method 320 

HF and HCl emissions 40 CFR 63 Subpart JJJJJ Table 

3, #1 e 

40 CFR 60 Appendix A, Method 5  PM  40 CFR 63 Subpart JJJJJ Table 

3, #1 f

· For Plant #4, the permittee must determine the production rate during each test run, include production

data collected during the performance tests in the test report, and must record the production rate on a 

fired product basis of the kiln for each of the three test runs.

(9 VAC 5­60­100, 40 CFR 63 Subpart JJJJJ, Table 3, #2)

· For Plant #4, the permittee must:

fi Document the source and grade of limestone used, fi Establish the operating limit for the lime feeder setting, fi Keep records of limestone purchased, fi Record data from the lime feeder during the performance test, and

fi Ensure that the lime in the feed hopper or silo to the scrubber is free flowing at all times during the

performance test. fi Record the feeder setting for the three test runs;

fi If the feed rate setting varies during the three test runs, the permittee must determine and record 

the average feed rate form the three test runs.

(9 VAC 5­60­100, 40 CFR 63 Subpart JJJJJ Table 3, #4)

Reporting

40 CFR 63 Subpart JJJJJ

The following notification and reporting requirements originate from the MACT:

· The permittee must report each instance in which Plant #4 did not meet each emission limit and each 

operating limit, including periods of startup, shutdown, malfunction, and routine control device 

maintenance.  These instances are deviations from the emission limitations in 40 CFR 63 Subpart

JJJJJ.

(9 VAC 5­60­100, 40 CFR 63.8470(c))

· The permittee shall submit a Notification of Compliance Status, including performance test results, before the close of business on the 60th calendar day following the completion of the performance test. The Notification of Compliance Status shall also contain the operating limit parameter values

established for ES­4­SCRB with supporting documentation and a description of the procedure used to 

establish the values.

(9 VAC 5­60­100, 40 CFR 63.8480(e), 40 CFR 63.10(d)(2))

· Semiannually the permittee shall submit a Compliance Report:

fi The first compliance report must cover the period beginning with startup and ending on June 30 or
Brick and Tile Corporation of Lawrenceville 

Plants 3 and 4 

PRO­30872 

Statement of Basis

Page 25 

December 31, and lasting at least 6 months, but less than 12 months.

fi The first compliance report must be postmarked or delivered no later than July 31 or January 31

for compliance periods ending June 30 and December 31, respectively. fi Each subsequent compliance report must cover the semiannual reporting period from January 1 

through June 30 or the semiannual reporting period from July 1 through December 31. fi Each subsequent compliance report must be postmarked or delivered no later than July 31 or

January 31 for compliance periods ending on June 30 and December 31, respectively.

(9 VAC 5­60­100, 40 CFR 63.8485(b)(1))

It should be noted that the compliance reporting requirement in the general provisions will be modified

to ensure that it matches these requirements.

· The semiannual compliance reports shall contain the following information:

fi Company name and address;

fi Statement by a responsible official with  that official’s name, title, and signature, certifying that, based on the information and belief formed after reasonable inquiry, the statements and 

information in the report are true, accurate, and complete;

fi Date of report and beginning and ending dates of the reporting period;

fi Information in 63.10(d)(5)(i)

fi A description of control device maintenance performed while ES­4­SCRB was offline and the kiln 

ES­4­K was running, including the information below: ß The date and time when the control device was shutdown and restarted; ß Identification of the kiln that was operating and the number of hours that the kiln operated wile 

the control device was offline;

fi If there are no deviations from any emission limitations or operating limits, the compliance report

shall contain a statement that there were no deviations from the emission limitations during the

reporting period;

fi If there were no periods during which the CMS was out­of­control as specified in the OM&M plan,

the compliance report shall contain a statement that there were no periods during which the CMS

was out­of­control during the reporting period.

(9 VAC 5­60­100, 40 CFR 63.8485(c), 40 CFR 63.10(d)(5)(i), 40 CFR 63 Subpart JJJJJ Table 6 #1a)

· For each deviation from an emission limit or operating limit occurring at Plant #4, the permittee must

include the following information in the compliance report. This includes periods of startup, shutdown, 

and malfunction. fi The total operating time of ES­4­K during the reporting period;

fi The date and time that each malfunction started and stopped;

fi The date and time that each CMS was inoperative, except for zero(low­level) and high­level 

checks;

fi The date, time, and duration that each CMS was out­of­control including the pertinent information

in the OM&M plan;

fi The date and time that each deviation started and stopped and whether each deviation occurred

during a period of startup, shutdown, malfunction, or during another period. fi A description of corrective action taken;

fi A summary of the total duration of the deviation during the reporting period and the total duration as

a percent of the total source operating time during that reporting period. fi A breakdown of the total duration of the deviations during the reporting period into those that were 

due to startup, shutdown, control equipment problems, process problems, other know causes, and 

other unknown causes;
Brick and Tile Corporation of Lawrenceville 

Plants 3 and 4 

PRO­30872 

Statement of Basis

Page 26

fi A summary of the total duration of the CMS downtime during the reporting period and the total 

duration of CMS downtime as a percent of the total source operating time during that reporting

period;

fi A brief description of the process units;

fi A brief description of the CMS;

fi The date of the latest CMS certification or audit;

fi A description of any changes in CMS, processes, or control equipment since the last reporting

period.

(9 VAC 5­60­100, 40 CFR 63.8485(e), 40 CFR 63 Subpart JJJJJ Table 6, #1.b. and c.)

· The permittee shall submit by fax or telephone within 2 working days an immediate startup, shutdown, 

and malfunction report if actions during a startup, shutdown, or malfunction are not consistent with the

SSMP. The report must contain the following information:

fi Name, title, and signature of the permittee or other responsible official who is certifying its

accuracy;

fi Explanation of the circumstances of the event;

fi Reasons for not following the SSM plan;

fi Description of all excess emissions and/or parameter monitoring exceedances which are believed

to have occurred;

(9 VAC 5­60­100, 40 CFR 63 Subpart JJJJJ Table 6 #2.a, 40 CFR 63.10(d)(5)(ii))

· The permittee shall submit by letter within 7 working days after the end of the event, unless other

arrangements have been made with the Director, Piedmont Region, a startup, shutdown, and 

malfunction report if actions during a startup, shutdown, or malfunction are not consistent with the

SSMP. The letter must contain the following information:

fi Name, title, and signature of the permittee or other responsible official who is certifying its

accuracy;

fi Explanation of the circumstances of the event;

fi Reasons for not following the SSM plan;

fi Description of all excess emissions and/or parameter monitoring exceedances which are believed

to have occurred;

(9 VAC 5­60­100, 40 CFR 63 Subpart JJJJJ Table 6 #2.b, 40 CFR 63.10(d)(5)(ii))

FACILITY WIDE APPLICABLE REQUIREMENTS

Limitations

Limitations from the NSR permit dated 8/16/2004:

· Fugitive Dust Emission Controls ­ Fugitive emission controls for Plant #3 and Plant #4 shall include 

the following, or equivalent, as a minimum:

a.  Dust from material handling and load­outs shall be controlled as specified in this permit.

b.  All material being stockpiled shall be kept adequately moist to control dust during storage 

and handling or covered at all times to minimize emissions.

c. Dust from haul roads and traffic areas shall be controlled by the application of asphalt, water, suitable chemicals, or equivalent methods approved by the DEQ.
Brick and Tile Corporation of Lawrenceville 

Plants 3 and 4 

PRO­30872 

Statement of Basis

Page 27 

d.  Reasonable precautions shall be taken to prevent deposition of dirt on public roads and 

subsequent dust emissions. Dirt, product, or raw material spilled or tracked onto paved

surfaces shall be promptly removed to prevent particulate matter from becoming airborne.

(9 VAC 5­50­260, 9 VAC 5­50­20, 9 VAC 5­50­90, Condition 15 of 8/16/2004 NSR permit)

· Requirements by Reference – Except where the NSR permit dated 8/16/2004 is more restrictive than 

the applicable requirement, the permittee shall operate the designated equipment listed in Condition 2 

of the 8/16/2004 NSR permit in compliance with 40 CFR 60, Subpart OOO, New Source Performance 

Standards for Nonmetallic Mineral Processing Plants and 40 CFR 63, Subpart JJJJJ, National 

Emission Standards for Hazardous Air Pollutants for Brick and Structural Clay Products Manufacturing.

(9 VAC 5­50­400, 9 AC 50­50­410, 9 VAC 5­60­100, Condition 45 of the 8/16/2004 NSR permit)

Record Keeping

Record keeping requirements from the 8/16/2004 NSR permit:

· On Site Records ­ The permittee shall maintain records of emission data and operating parameters as

necessary to demonstrate compliance with this permit. The content and format of such records shall 

be arranged with the Director, Piedmont Region. These records shall include, but are not limited to: 

a.  Annual production of fired brick from Plant #3, calculated monthly as the sum of each 

consecutive 12 month period.

b.  Annual production of fired brick from Plant #4, calculated monthly as the sum of each 

consecutive 12 month period.

c. Operation and control device monitoring records for the fabric filter dust collection systems

controlling the Plant #3 grinding room and the Plant #3 texturing and coating equipment.

d.  Operation and control device monitoring records for the Plant #4 baghouses designated 

ES­4­GR and ES­4­MR, including records showing the periods when the baghouse ES­4­

MR was not in operation while the brick making room was running operations other than 

dry coating operations.

e.  Operation and control device monitoring records for the Plant #4 dry hydrated lime 

injection baghouse system designated ES­4­SCRB as described in Condition 20 of the

8/16/2004 NSR permit.

f. Test data showing raw material fluoride and sulfur content and material balance 

information as described in Conditions 59 and 60 of the 8/16/2004 NSR permit.

g.  Results of all stack tests, visible emission evaluations and performance evaluations.

h.  Scheduled and unscheduled maintenance, and operator training.

These records shall be available for inspection by the DEQ and shall be current for the most recent five 

years.

(9 VAC 5­50­50, Condition 46 of the 8/16/2004 NSR permit, 40 CFR 63 Subpart JJJJJ Table 5 #2)
Brick and Tile Corporation of Lawrenceville 

Plants 3 and 4 

PRO­30872 

Statement of Basis

Page 28 

Record keeping requirements from Subpart JJJJJ are included in Plant #4’s applicable requirements listing

above.

Testing

· Stack Test ­ Initial performance tests shall be conducted for particulate matter, PM10  , carbon 

monoxide, sulfur dioxide, hydrogen fluoride, and hydrogen chloride from the exhaust of the dry hydrated 

lime injection baghouse (ES­4­SCRB) controlling the Plant #4 tunnel kiln (ES­4­K) to determine

compliance with the emission limits and control efficiency requirements contained in Conditions 35 and 

8 of the 8/16/2004 NSR permit. The tests shall be performed and demonstrate compliance no later

than 180 days after initial start­up of the permitted facility. Tests shall be conducted and reported and 

data reduced as set forth in 9 VAC 5­50­30 and 9 VAC 5­60­30 and the test methods and procedures

contained in each applicable section or subpart listed in 9 VAC 5­50­410 and 9 VAC 5­60­70. The

details of the tests are to be arranged with the Director, Piedmont Region. During the test runs the

permittee shall record the lime feeder setting. The test results shall contain records of this parameter. The permittee shall submit a test protocol at least 60 days prior to testing. Two copies of the test

results shall be submitted to the Director, Piedmont Region within 60 days after test completion and 

shall conform to the test report format enclosed with this permit.

(9 VAC 5­50­30, 9 VAC 5­80­1200, Condition 54 of the 8/16/2004 NSR permit, 40 CFR 63 Subpart

JJJJJ Table 4 #2))

· Testing/Monitoring Ports ­ The permitted facility shall be constructed so as to allow for emissions

testing upon reasonable notice at any time, using appropriate methods. This includes constructing the

facility such that volumetric flow rates and pollutant emission rates can be accurately determined by

applicable test methods and providing stack or duct that is free from cyclonic flow. Test ports shall be

provided at the appropriate locations.

(9 VAC 5­50­30 F, Condition 47 of the 8/16/2004 NSR permit)

Obsolete Conditions

The following conditions are obsolete since the facility has already completed the requirements.

1. Initial Notifications ­ The permittee shall furnish written notification to the Director, Piedmont

Region:

a.  The actual date on which construction of Plant #4 commenced within 30 days after such 

date. 

b.  The anticipated start­up date of Plant #4 postmarked not more than 60 days nor less than 

30 days prior to such date.

c. The actual start­up date of Plant #4 within 15 days after such date.

d.  The anticipated date of performance tests of Plant #4 postmarked at least 30 days prior to 

such date.

Copies of the written notification referenced in items a through c above are to be sent to: 

Associate Director

Office of Air Enforcement (3AP10)
Brick and Tile Corporation of Lawrenceville 

Plants 3 and 4 

PRO­30872 

Statement of Basis

Page 29 

U.S. Environmental Protection Agency

Region III

1650 Arch Street

Philadelphia, PA 19103­2029

(9 VAC 5­50­50, Condition 61 of the 8/16/2004 NSR permit)

2.  The following Initial Performance Testing requirements originate in the 8/16/2004 NSR permit:

a. Stack Test ­ Initial performance tests shall be conducted for particulate matter and PM10 

from the exhaust of the baghouse designated ES­4­GR to determine compliance with the

emission limits and control efficiency requirements contained in Conditions 31 and 10 of

the 8/16/2004 NSR permit. The tests shall be performed and shall demonstrate 

compliance within 60 days after achieving the maximum production rate at which the facility

will be operated but in no event later than 180 days after start­up of the permitted facility. Tests shall be conducted and reported and data reduced as set forth in 9 VAC 5­50­30

and the test methods and procedures contained in each applicable section or subpart

listed in 9 VAC 5­50­410.  The details of the tests are to be arranged with the Director, Piedmont Region. During each test run, the permittee shall note the differential pressure 

of the baghouse and include this information in the testing report. The permittee shall 

submit a test protocol at least 30 days prior to testing. Two copies of the test results shall 

be submitted to the Director, Piedmont Region within 60 days after test completion and 

shall conform to the test report format enclosed with this permit.

(9 VAC 5­50­30, 9 VAC 5­80­1200, 9 VAC 5­50­410, Condition 49 of the 8/16/2004 NSR 

permit, 40 CFR 60.675 (b))

b. Visible Emissions Evaluation ­ Concurrently with the initial performance tests, Visible 

Emission Evaluations (VEE) in accordance with 40 CFR Part 60, Appendix A, Method 9, 

shall also be conducted by the permittee on the exhaust of the baghouse designated ES­4­

GR. Each test shall consist of 30 sets of 24 consecutive observations (at 15 second 

intervals) to yield a six minute average.  The details of the tests are to be arranged with the

Director, Piedmont Region. The permittee shall submit a test protocol at least 30 days

prior to testing. The evaluation shall be performed and shall demonstrate compliance 

within 60 days after achieving the maximum production rate at which the facility will be

operated but in no event later than 180 days after start­up of the permitted facility. Should 

conditions prevent concurrent opacity observations, the Director, Piedmont Region shall be

notified in writing, within seven days, and visible emissions testing shall be rescheduled

within 30 days. Rescheduled testing shall be conducted under the same conditions (as

possible) as the initial performance tests. Two copies of the test result shall be submitted

to the Director, Piedmont Region within 45 days after test completion and shall conform to 

the test report format enclosed with this permit.

(9 VAC 5­50­30, 9 VAC 5­80­1200, 9 VAC 5­50­410, Condition 50 of the 8/16/2004 NSR 

permit, 40 CFR 675(b))

c. Definition of Initial Start­Up – For applicability to the testing required in Conditions 52, 53, and 54 of the 8/16/2004 NSR permit, initial start­up shall mean the time at which Plant #4

tunnel Kiln (ES­4­K) first reaches a level of production that is equal to 75% of the kiln 

design capacity or 12 months after the unit begins firing brick, whichever is earlier.

(9 VAC 170­160, 9 VAC 5­60­100, Condition 51 of the 8/16/2004 NSR permit, 40 CFR

63.8515)
Brick and Tile Corporation of Lawrenceville 

Plants 3 and 4 

PRO­30872 

Statement of Basis

Page 30 

d. Stack Test ­ Initial performance tests shall be conducted for particulate matter and PM10 

from the exhaust of the baghouse designated ES­4­MR to determine compliance with the

emission limitations contained in Condition 33 of the 8/16/2004 NSR permit. The tests

shall be performed and shall demonstrate compliance no later than 180 days after initial 

start­up of the permitted facility. Tests shall be conducted and reported and data reduced

as set forth in 9 VAC 5­50­30 and the test methods and procedures contained in each 

applicable section or subpart listed in 9 VAC 5­50­410.  The details of the tests are to be 

arranged with the Director, Piedmont Region. During each test run, the permittee shall 

note the differential pressure of the baghouse and include this information in the testing

report. The permittee shall submit a test protocol at least 60 days prior to testing. Two 

copies of the test results shall be submitted to the Director, Piedmont Region within 60 

days after test completion and shall conform to the test report format enclosed with this

permit.

(9 VAC 5­50­30, 9 VAC 5­80­1200, Condition 52 of the 8/16/2004 NSR permit)

e. Visible Emissions Evaluation ­ Concurrently with the initial performance tests, Visible 

Emission Evaluations (VEE) in accordance with 40 CFR Part 60, Appendix A, Method 9, 

shall also be conducted by the permittee on the exhaust of the baghouse designated ES­4­

MR. Each test shall consist of ten sets of 24 consecutive observations (at 15 second 

intervals) to yield a six minute average.  The details of the tests are to be arranged with the

Director, Piedmont Region. The permittee shall submit a test protocol at least 60 days

prior to testing. The evaluation shall be performed and demonstrate compliance no later

than 180 days after initial start­up of the permitted facility. Should conditions prevent

concurrent opacity observations, the Director, Piedmont Region shall be notified in writing, within seven days, and visible emissions testing shall be rescheduled within 30 days. Rescheduled testing shall be conducted under the same conditions (as possible) as the

initial performance tests. Two copies of the test results shall be submitted to the Director, Piedmont within 60 days after test completion and shall conform to the test report format 

enclosed with this permit.

(9 VAC 5­50­30, 9 VAC 5­80­1200, Condition 53 of the 8/16/2004 NSR permit)

f. Visible Emissions Evaluation ­ Visible Emission Evaluations (VEE) in accordance with 40 

CFR Part 60, Appendix A, Method 9, shall be conducted by the permittee on the equipment

listed in Condition 40 of the 8/16/2004 NSR permit. Each test shall consist of 30 sets of 24

consecutive observations (at 15 second intervals) to yield a six minute average.  The details

of the tests are to be arranged with the Director, Piedmont Region. The permittee shall 

submit a test protocol at least 30 days prior to testing. The evaluation shall be performed

and demonstrate compliance within 60 days after achieving the maximum production rate 

at which the facility will be operated but in no event later than 180 days after start­up of the

permitted facility. Two copies of the test result shall be submitted to the Director, Piedmont

Region within 60 days after test completion and shall conform to the test report format 

enclosed with this permit.

(9 VAC 5­50­30, 9 VAC 5­80­1200, 9 VAC 5­50­410, Condition 55 of the 8/16/2004 NSR 

permit, 40 CFR 60.675(b))

g. Visible Emissions Evaluation­ Visible Emission Evaluations required in Condition 55 on

the equipment listed in Condition 40 of the 8/16/2004 NSR permit may be reduced to ten

(10) sets of twenty­four (24) consecutive observations (at fifteen (15) second intervals) to 

yield a six (6) minute average if:

1.  There are no individual readings greater than ten (10) percent opacity for
Brick and Tile Corporation of Lawrenceville 

Plants 3 and 4 

PRO­30872 

Statement of Basis

Page 31 

each piece of equipment, and 

2.  There are no more than three (3) readings of ten (10) percent opacity for

the one (1) hour period for each piece of equipment.

(9 VAC 5­50­410, Condition 56 of the 8/16/2004 NSR permit, 40 CFR 60.675 (c)(3))

h. Visible Emissions Evaluation ­ Visible Emission Evaluations (VEE) in accordance with 40 

CFR Part 60, Appendix A, Method 9, shall be conducted by the permittee on the Plant #4

roll crusher, ES­4­CR1. Each test shall consist of 30 sets of 24 consecutive observations

(at 15 second intervals) to yield a six minute average.  The details of the tests are to be 

arranged with the Director, Piedmont Region. The permittee shall submit a test protocol at 

least 30 days prior to testing. The evaluation shall be performed and demonstrate 

compliance within 60 days after achieving the maximum production rate at which the facility

will be operated but in no event later than 180 days after start­up of the permitted facility. Two copies of the test result shall be submitted to the Director, Piedmont Region within 60 

days after test completion and shall conform to the test report format enclosed with this

permit.

(9 VAC 5­50­30, 9 VAC 5­80­1200, and 9 VAC 5­50­410, Condition 57 of the 8/16/2004 

NSR permit, 40 CFR 60.675(b))

i. Visible Emissions Evaluation­ Visible Emission Evaluations required in Condition 57 of 

the 8/16/2004 NSR permit on the Plant #4 roll crusher, ES­4­CR1, may be reduced to ten

(10) sets of twenty­four (24) consecutive observations (at fifteen (15) second intervals) to 

yield a six (6) minute average if:

1.  There are no individual readings greater than fifteen (15) percent opacity

for each piece of equipment, and 

2.  There are no more than three (3) readings of fifteen (15) percent opacity

for the one (1) hour period for each piece of equipment.

(9 VAC 5­50­410, Condition 58 of the 8/16/2004 NSR permit, 40 CFR 60.675(c)(4))

Many of the MACT conditions for initial notification concerning Plant #4 (ES­4­K) have also been performed. These include:

· The permittee shall submit an Initial Notification not later than 120 calendar days after startup.

(9 VAC 5­60­100, 40 CFR 63.8480(c))

· The permittee shall submit a Notification of Intent to Conduct a Performance Test at least 60 calendar

days prior to the scheduled date. 

(9 VAC 5­60­100, 40 CFR 63.8480(d), 40 CFR 63.7(b)(1))

Streamlined Requirements

Plants #3 & #4 Subpart OOO:

Plants #3 and #4 have a number of pieces of equipment that are subject to standards under 40 CFR 60

Subpart OOO. All requirements in the NSR permit dated 8/16/2004 are at least as stringent as those
Brick and Tile Corporation of Lawrenceville 

Plants 3 and 4 

PRO­30872 

Statement of Basis

Page 32 

required by Subpart OOO. Therefore, the NSR permit conditions will be used for the Subpart OOO

applicabilities. The appropriate paragraphs of Subpart OOO will be referenced behind each condition. Where the NSR permit makes no mention of Subpart OOO requirements, as noted in the limitations above, 

these requirements will be included in the Title V permit.

PERIODIC MONITORING REQUIREMENTS AND CAM REQUIREMENTS

Compliance Assurance Monitoring (CAM)

CAM requirements apply to units that use a control device and that would have a potential to emit of more 

than 100 tpy of criteria pollutants prior to control. CAM also does not apply to standards that have been 

developed after 11/15/1990. The control devices at this facility, baghouses controlling various particulate 

sources, bin vents controlling silos, and the dry lime injection baghouse controlling the Kiln #4, do not meet

the requirements for the application of CAM. The baghouses and bin vents controlling various particulate 

sources do not have a pre control PTE of more than 100 tpy of PM10. The dry lime injection baghouse is

regulated by 40 CFR 63 Subpart JJJJJ for PM and for HAPS and therefore is not subject to CAM for these 

pollutants. The NSR permit dated 8/16/2004 requires a 30% SO2 removal efficiency by this control device; 

however, the pre­control PTE is less than 100 tpy of SO2. Based on these facts, no CAM determination

have been included in this Title V permit.

Periodic Monitoring

It should be noted that the following table does not contain periodic monitoring for any of the requirements

originating in 40 CFR 63 Subpart JJJJJ. Since this MACT standard was promulgated after 1990, it is

assumed that the monitoring, record keeping, and recording required by the standard itself are sufficient to 

demonstrate compliance. 

Conditions for monitoring, testing, record keeping and reporting have been added to the Title V permit to 

satisfy the requirements of the table below such that periodic monitoring may provide sufficient assurance 

of compliance with limitations.

Periodic Monitoring Requirements for Brick and Tile Corporation of Lawrenceville 30872

Limitation  Parameter  Monitoring Record Keeping Reporting

Plant #3 tunnel kiln (ES­3­K) 

PM/PM10:  21.3 lbs/hr  79.2 tpy

SO2

9.9 lbs/hr   36.9 tpy

NO2

5.2 lbs/hr   19.3 tpy

CO

17.8 lbs/hr  66.0 tpy

VOC 

0.4 lbs/hr   1.3 tpy

*kiln rating/capacity; 

*annual brick

produced

*stack test data once

every 5 years. 

*S content of raw  materials

*Visible emissions

*S content of raw  material; 

*requirement for  procedures to be written down

*Visible emission

checks monthly

*rating/capacity. 

*emission factors

*emission calculations

*training certifications

*test data

*Results of monthly

visible emission checks

Quarterly, reporting changes in

parameters for calculations

See Emission Limitation Demonstration. 

Stack test report.

Plant #3 tunnel kiln dryer (ES­3­BD)
Brick and Tile Corporation of Lawrenceville 

Plants 3 and 4 

PRO­30872 

Statement of Basis

Page 33

Periodic Monitoring Requirements for Brick and Tile Corporation of Lawrenceville 30872

Limitation  Parameter  Monitoring Record Keeping Reporting

PM/PM10:  2.8 lbs/hr  10.3 tpy

NO2

1.5 lbs/hr   5.4 tpy

CO

4.6 lbs/hr  17.1 tpy

VOC 

0.5 lbs/hr   1.7 tpy

*dryer 

rating/capacity; 

*annual brick

production

*good operating

practices

*Visible emissions

*training of operators; 

*requirement for  procedures to be written down

*Visible emission

checks monthly

*kiln rating/capacity. 

*emission factors

*emission calculations

*training certifications

*Results of monthly

visible emission

checks. 

Quarterly, reporting changes in

parameters for calculations

See Emission Limitation Demonstration. 

#3 grinding room baghouse (ES­3­GR­BH) 

TSP & PM10

.02 gr/dscft 

5.8 lbs/hr  8.6 tpy

7% opacity

pressure drop

across baghouse

visual checks to

determine if visible

emissions are

present 

Check pressure drop

once per shift to ensure

it is within manufacturer’s

recommendations

Check visible

emissions 1/month while operating

Record pressure drop

once per shift 

visible emission check

records

Record instances where

pressure drop exceeds manufacturer’s

recommendations. 

Report instances where

emissions checks show opacity

problems. 

See Emission Limitation Demonstration

#3 making room baghouse room (ES­3­MR­BH) 

TSP & PM10

0.01 gr/dscft 

1.6 lbs/hr  1.6 tpy

5% opacity

99% control efficiency

pressure drop

across baghouse

visual checks to

determine if visible

emissions are

present 

Check pressure drop

once per shift to ensure

it is within manufacturer’s

recommendations

Check visible

emissions 1/month while operating

Record pressure drop

once per shift 

visible emission check

records

Record instances where

pressure drop exceeds manufacturer’s

recommendations. 

Report instances where

emissions checks show opacity

problems. 

See Emission Limitation Demonstration Plant #3 NSPS Subpart OOO requirements

ES­3­CR1 Roll Crusher  15% opacity

ES­3­C1A conveyor  10% opacity

ES­3­C2 conveyor  10% opacity

ES­3­C11 through C13

conveyors 10% opacity

visual checks to

determine if visible

emissions are

present 

Check visible

emissions 1/month while operating

visible emission check

records Report instances whereemissions checks show opacity

problems

Plant #3 total emissions
Brick and Tile Corporation of Lawrenceville 

Plants 3 and 4 

PRO­30872 

Statement of Basis

Page 34

Periodic Monitoring Requirements for Brick and Tile Corporation of Lawrenceville 30872

Limitation  Parameter  Monitoring Record Keeping Reporting

PM/PM10

31.4 lbs/hr  99.7 tpy

SO2

9.9 lbs/hr  36.9 tpy

NO2

6.6 lbs/hr  24.6 tpy

CO

22.4 lbs/hr  83.1 tpy

VOC 

0.8 lbs/hr  3.0 tpy

summation of Plant 

#3 requirements as above

summation of Plant #3

requirements as above

summation of Plant #3

requirements as above Report semiannually uponemissions status. 

Plant #4 grinding room baghouse (ES­4­GR­BH) 

PM/PM10

99% control efficiency

0.022 gr/dscft 

5.0 lbs/hr  22.1 tpy

7% opacity

pressure drop

across baghouse

visual checks to

determine if visible

emissions are

present 

Check pressure drop

once per shift to ensure

it is within manufacturer’s

recommendations

Check visible

emissions 1/month while operating

Record pressure drop

once per shift 

visible emission check

records

Record instances where

pressure drop exceeds manufacturer’s

recommendations. 

Report instances where

emissions checks show opacity

problems. 

See emission limitation

demonstration. 

Plant #4 making room baghouse (ES­4­MR­BH) 

PM/PM10

99% control efficiency

0.01 gr/dscf 

1.2 lbs/hr  5.3 tpy

5% opacity

pressure drop

across baghouse

visual checks to

determine if visible

emissions are

present 

Check pressure drop

once per shift to ensure

it is within manufacturer’s

recommendations

Check visible

emissions 1/month while operating

Record pressure drop

once per shift 

visible emission check

records

Record instances where

pressure drop exceeds manufacturer’s

recommendations. 

Report instances where

emissions checks show opacity

problems. 

See emission limitation

demonstration Plant #4 truck dumping and crushing

PM/PM10

3.8 lbs/hr  16.6 tpy

annual production of 

brick; 

emission factors

production production, emission

factors, and formulas

semiannually, when factors

change or production is too high. 

See emission limitation

demonstration. 

Plant #4 ground material storage
Brick and Tile Corporation of Lawrenceville 

Plants 3 and 4 

PRO­30872 

Statement of Basis

Page 35

Periodic Monitoring Requirements for Brick and Tile Corporation of Lawrenceville 30872

Limitation  Parameter  Monitoring Record Keeping Reporting

PM/PM10

2.7 lbs/hr  11.8 tpy

annual production of 

brick; 

emission factors

production production, emission

factors, and formulas

semiannually, when factors

change or production is too high. 

See emission limitation

demonstration Plant #4 tunnel kiln dryer (ES­4­BD) 

PM/PM10:  2.8 lbs/hr  12.1 tpy

NO2

1.5 lbs/hr   6.4 tpy

CO

4.6 lbs/hr  20.1 tpy

VOC 

0.4 lbs/hr   1.97 tpy

*dryer 

rating/capacity; 

*annual brick

production

*good operating

practices

*training of operators; 

*requirement for  procedures to be written down

*kiln rating/capacity. 

*emission factors

*emission calculations

*training certifications

Quarterly, reporting changes in

parameters for calculations

See Emission Limitation Demonstration. 

Plant #4 tunnel kiln scrubber(ES­4­SCRB) 

SO2

6.9 lbs/hr  30.4 tpy  30% ce NO2

5.2 lbs/hr  22.5 tpy

CO

17.8 lbs/hr  77.8 tpy

VOC 

0.4 lbs/hr  1.6 tpy

*kiln rating/capacity; 

*annual brick

produced

*stack test data once

every 5 years.  *S content of raw  materials

*scrubber monitoring

as for HF/HCL in MACT 

*S content of raw  material; 

*requirement for  procedures to be written down MACT monitoring (acid

gases) 

*rating/capacity.  *emission factors

*emission calculations

*training certifications

*test data

*parametric monitoring

from MACT 

Quarterly, reporting changes in

parameters for calculations

See Emission Limitation Demonstration. 

Stack test report.

Plant #4 NSPS Subpart OOO requirements

ES­4­CR1 Roll Crusher  15% opacity

ES­4­C1 conveyor  ES­4­C2 conveyor  ES­4­C3 conveyor  ES­4­C5 conveyors ES­4­C6SR conveyor  ES­4­C16B conveyor  ES­4­C16C conveyor  ES­4­C19 conveyor  ES­4­C18SR conveyor  ES­4­C18W conveyor  ES­4­C18E conveyor  10% opacity

visual checks to

determine if visible

emissions are

present 

Check visible

emissions 1/month while operating

visible emission check

records Report instances whereemissions checks show opacity

problems

Plant #4 sand storage silo (ES­4­SS) and Plant #4 lime storage silo (ES­4­LS) 

5% opacity visible emissions monthly sighting and

evaluation

records of monthly

sightings

semiannually, times when silos exhibited visible emissions Plant #4 total emissions
Brick and Tile Corporation of Lawrenceville 

Plants 3 and 4 

PRO­30872 

Statement of Basis

Page 36

Periodic Monitoring Requirements for Brick and Tile Corporation of Lawrenceville 30872

Limitation  Parameter  Monitoring Record Keeping Reporting

PM/PM10

17.3 lbs/hr  75.7 tpy

SO2

6.9 lbs/hr  30.4 tpy

NO2

6.6 lbs/hr  29.0 tpy

CO

22.3 lbs/hr  97.9 tpy

VOC 

0.8 lbs/hr  3.5 tpy

summation of Plant 

#4 requirements as above

summation of Plant #4

requirements as above

summation of Plant #4

requirements as above Report semiannually uponemissions status.

Emission Limitation Demonstration: The purpose of this demonstration is to show that if the facility

meets the standards prescribed in the permit for the following

equipment and does not exceed the maximum rated capacities for

each piece of equipment, the facility will remain in compliance 

with their lbs/hr, tons/year, and tons/year/facility emissions limits. See the spreadsheet in Attachment 2.

Kiln #3 and Kiln #4:

Given: Kiln #3 rated at 14.8 tons fired brick/hr

Maximum throughput limit of 110,000 tpy fired brick

AP­42 emission factors from Table 11.3­1, 8/97 AP­42 for all pollutants except VOC & PM 

AP­42 emission factors from Table 11.3­5, 8/97 AP­42 for VOC

Test data from July 18, 2000 stack test used for PM & PM 10.

Listed below are the formulas which apply to the following pollutants:

lbs/hr = (lbs/ton fired brick)(rating of dryer)

tpy = (lbs/ton fired brick)(maximum throughput)(1 ton/2000 lbs) 

NOx: 0.35 lbs/ton( 14.8 tons/hr) = 5.2 lbs/hr

0.35 lbs/ton( 110000 tons/yr)(1 ton/2000 lbs) = 19.3 tons/yr

TSP/PM10: 1.44 lbs/ton( 14.8 tons/hr) = 21.3 lbs/hr

1.44 lbs/ton( 110000 tons/yr)(1 ton/2000 lbs) = 79.2 tpy

CO:  1.2 lbs/ton brick( 14.8 tons/hr) = 17.8 lbs/hr

1.2 lbs/ton brick(110000 tons/yr)(1 ton/2000 lbs) = 66 tpy

VOC: 0.024 lbs/ton( 14.8 tons/hr) = 0.4 lbs/hr

0.024 lbs/ton( 110000 tons/yr)(1 ton/2000 lbs) = 1.3 tpy

The attached spreadsheet details these calculations and also provides similar calculations for #4 Kiln.  It

should be noted that for #4 kiln, no emission limitation demonstration is needed for particulate matter since 

the particulate matter standard of 0.12 lbs/ton is a MACT standard, which provides sufficient monitoring

requirements for periodic monitoring purposes.
Brick and Tile Corporation of Lawrenceville 

Plants 3 and 4 

PRO­30872 

Statement of Basis

Page 37

Kiln Dryer #3 and Kiln Dryer #4:

Given: Kiln #3 dryer with a 9 mmbtu/hr gas/propane burner, rated at 14.8 tons fired brick/hr

Maximum throughput limit of 110,000 tpy fired brick

AP­42 emission factors from Table 11.3­1, 8/97 AP­42 for all pollutants except VOC

AP­42 emission factors from Table 11.3­5, 8/97 AP­42 for VOC

Listed below are the formulas which apply to the following pollutants:

lbs/hr = (lbs/ton fired brick)(rating of dryer)

tpy = (lbs/ton fired brick)(maximum throughput)(1 ton/2000 lbs) 

NOx: 0.098 lbs/ton( 14.8 tons/hr) = 1.5 lbs/hr

0.098 lbs/ton( 110000 tons/yr)(1 ton/2000 lbs) = 5.4 tons/yr

TSP/PM10: 0.187 lbs/ton( 14.8 tons/hr) = 2.8 lbs/hr

0.187 lbs/ton( 110000 tons/yr)(1 ton/2000 lbs) = 10.3 tpy

CO:  0.31 lbs/ton brick( 14.8 tons/hr) = 4.6 lbs/hr

0.31 lbs/ton brick(110000 tons/yr)(1 ton/2000 lbs) = 17.1 tpy

VOC: 0.03 lbs/ton( 14.8 tons/hr) = 0.4 lbs/hr

0.03 lbs/ton( 110000 tons/yr)(1 ton/2000 lbs) = 1.7 tpy

The attached spreadsheet shows that Kiln #4 dryer will also meet its limitations if the AP­42 emission

factors are used and if they remain beneath their throughput limitations.

#3 grinding room baghouse

Given: Maximum air flow of baghouse = 33600 acfm 

Permit limits facility to 110000 tons annually. Loss on ignition of 5% by weight. 30% recycle to the grinding room. 90 tons/hr grinder maximum capacity. Limit of 0.02 gr/dscft (manufacturer’s guarantee)

TSP/PM10  :

Tons of material ground annually: 110000 tons fired brick/year*1.3/(1­.05)=150526 tons ground annually

Hours of operation annually: 150526 tons ground/90 tons/hr=1672 hours/year < 3000 hrs/yr (assumption

used for annual calculation.)

33600 acfm*60 min/hr*0.02 gr/dscft*1 lb/7000 gr= 5.78 lbs/hr

5.87 lbs/hr*3000 hrs/year*1ton/2000 lbs=8.64 tons/yr

Similar calculations are shown in the attached spreadsheet for #3 making room baghouse (ES­3­MR­BH), #4 grinding room baghouse (ES­4­GR­BH), #4 making room baghouse (ES­4­MR­BH), #4 dumping and 

crushing, and #4 ground material storage.
Brick and Tile Corporation of Lawrenceville 

Plants 3 and 4 

PRO­30872 

Statement of Basis

Page 38

GENERAL CONDITIONS

The permit contains general conditions required by 40 CFR Part 70 and 9 VAC 5­80­110 that applies to all 

Federal Operating permit sources. These include requirements for submitting semi­annual monitoring

reports and an annual compliance certification report. The permit also requires notification of deviations

from permit requirements or any excess emissions.

Comments on General Conditions 

B. Permit Expiration

This condition refers to the Board taking action on a permit application. The Board is the State Air

Pollution Control Board. The authority to take action on permit application(s) has been delegated to the

Regions as allowed by §§ 2.1­20.01:2 and §10.1­1185 of the Code of Virginia, and the “Department of 

Environmental Quality Agency Policy Statement No. 3­2001”.

F. Failure/Malfunction Reporting

Section 9 VAC 5­20­180 requires malfunction and excesses emissions reporting within 4 hours. Section 9 VAC 5­80­250 also requires malfunction reporting; however, reporting is required within 2 

days. Section 9 VAC 5­20­180 is from the general regulations. All affected facilities are subject to this

section including Title 5 facilities. Section 9 VAC 5­80­250 is from the Title 5 regulations. Title 5 

facilities are subject to both Sections. A facility may make a single report that meets the requirements

of 9 VAC 5­20­180 and 9 VAC 5­80­250.  The report must be made within 4 day time business hours of 

the malfunction.

J.  Permit Modification

This general condition cites the sections that follow:

9 VAC 5­80­50 Applicability, Federal Operating Permit For Stationary Sources

9 VAC 5­80­190  Changes to Permits. 9 VAC 5­80­260  Enforcement. 9 VAC 5­80­1100 Applicability, Permits For New and Modified Stationary Sources

9 VAC 5­80­1790 Applicability, Permits For Major Stationary Sources and Modifications Located in 

Prevention of Significant Deterioration Areas

9 VAC 5­80­2000 Applicability, Permits for Major Stationary Sources and Major Modifications

Locating in Nonattainment Areas

U. Malfunction as an Affirmative Defense

The regulations contain two reporting requirements for malfunctions that coincide. The reporting

requirements are listed in section 9 VAC 5­80­250 and 9 VAC 5­20­180.  The malfunction requirements

are listed in General Condition U and General Condition F. For further explanation see the comments

on general condition F.

Y.  Asbestos Requirements

The Virginia Department of Labor and Industry under Section 40.1­51.20 of the Code of Virginia also
Brick and Tile Corporation of Lawrenceville 

Plants 3 and 4 

PRO­30872 

Statement of Basis

Page 39 

holds authority to enforce 40 CFR 61 subpart M, National Emission Standards for Asbestos.

STATE ONLY APPLICABLE REQUIREMENTS

There are not any state only requirements in this Title V permit.

FUTURE APPLICABLE REQUIREMENTS

As stated above, Plant #3 will be subject to 40 CFR 63 Subpart JJJJJ in 2006.  At that time, Plant #3 must

either take a federally enforceable limitation to 87,600 tons of fired brick per year or must install control 

equipment sufficient to allow it to meet the standards in 40 CFR 63 Subpart JJJJJ for large, existing kilns.

INAPPLICABLE REQUIREMENTS

The permittee identified no specific inapplicable requirements in the application.

COMPLIANCE PLAN

No compliance plan is needed for this facility.

INSIGNIFICANT EMISSION UNITS

No units are considered insignificant at this facility due to the new source review permitting status for Plants

#3 and Plants #4. Plant #3 was permitted as a synthetic minor source under minor new source review

permitting. The pollutant of concern was PM/PM10. The current NSR permit limits Plant #3 to 99.7 tpy of 

PM/PM10. This is appropriate since no public notice or public hearing, as required by the minor new source 

review regulations for “state major” facilities, was held.  Since all units at Plant #3 emit some PM10, no unit

may be considered insignificant since its contribution to the overall emissions cap must be evaluated for

compliance purposes.

Plant #4 was also permitted under the minor new source review regulations, prior to the promulgation of the

version YY regulations (9 VAC 5­80 Article 6). Therefore, since the currently permitted and operating

facility was a synthetic minor facility (<100 tpy of any criteria pollutant), an increase for the new facility of up

to 99 tpy could be allowed for criteria pollutants before “state major” requirements for public notice and

public hearing were triggered. It should be noted that version YY changed the public notice/public hearing

trigger to a past actual to future potential test. Kiln #4 was built with a dry lime injection baghouse and the

PM10 limitation for the entire Plant #4 is set at 75.5 tpy. For Plant #4, the pollutant of most concern is

carbon monoxide, which was permitted at 97.9 tpy. However, the PM10 limitation is based on after control 

emission factors and therefore all PM10 sources of emissions must be considered for the cap.

Therefore, all emission units are listed as significant emissions units for this permit.

CONFIDENTIAL INFORMATION

This permit contains no confidential information, nor does the application for the permit.

PUBLIC PARTICIPATION

The proposed permit was placed on public notice in the Richmond Times Dispatch on June 13, 2005 and 

ended on July 12, 2005. The Region 3 EPA forty­five day review period ended August 27, 2005.
Brick and Tile Corporation of Lawrenceville 

Plants 3 and 4 

PRO­30872 

Statement of Basis

Page 40 

Attachments:

Attachment 1:  2003 Annual update 

Attachment 2:  Emission limitation spreadsheets