___________________________________________________ _____________________________

Mooresville Regional Office

- Division of Air Quality 610 East Center Avenue, Suite 301, Mooresville, Nor th Carolina 28115 Phone: (704) 663-1699 \ FAX: (704) 663-7579 \ Inter net: www.ncair.org/

An Equal Opportunity \ Affirmative Action Employer The linked image cannot be displayed. The file may have been moved, renamed, or deleted. Verify that the link points to the correct file and location.



### North Carolina Department of Environment and Natura l Resources

Division of Air Quality Beverly Eaves Perdue Sheila C. Holman Dee Freeman
Governor Director Secretary

June 20, 2012

Mr. Burt Benfield
Vice President Taylor Clay Products, Inc.
Post Office Box 2128 Salisbury, NC 28145

Subject: Air Permit No. 05491R19 Taylor Clay Products, Inc. Salisbury, Rowan County, North Carolina Permit Class: Synthetic Minor Facility ID# 8000084

Dear Mr. Benfield:

In accordance with your completed application rece ived May 15, 2012, we are forwarding herewith Permit No. 05491R19 to Taylor Clay Product s, Inc., Salisbury, Rowan County, North Carolina for the construction and operation of air emissions sources or air cleaning devices and appurtenances. Please note the records retention re quirements are contained in General Condition 2
of the General Conditions and Limitations.

If any parts, requirements, or limitations contain ed in this permit are unacceptable to you, you have the right to request a formal adjudicatory hearing within 30 days following receipt of this permit, identifying the specific issues to be conte sted. Such a request will stay the effectiveness of the entire permit. This hearing request must be in the form of a written petition, conforming to G.S. 150B-23 of the North Carolina General Statutes, and filed with the Office of Administrative Hearings, 6714 Mail Service Center, Raleigh, NC 276 99-6714. The form for requesting a formal adjudicatory hearing may be obtained upon request f rom the Office of Administrative Hearings. Unless a request for a hearing is made pursuant to G.S. 150B-23, this air permit shall be final and binding.

You may request modification of your air permit th rough informal means pursuant to G.S. 150B-22. This request must be submitted in writing to the Director and must identify the specific provisions or issues for which the modification is sought. Please note that the permit will become final and binding regardless of a request for infor mal modification unless a request for a hearing is
also made under G.S. 150B-23. The linked image cannot be displayed. The file may have been moved, renamed, or deleted. Verify that the link points to the correct file and location.Burt Benfield

June 20, 2012 Page 2

Unless exempted by a condition of this permit or th e regulations, construction of new air pollution sources or air cleaning devices, or m odifications to the sources or air cleaning devices described in this permit must be covered un der a permit issued by the Division of Air Quality prior to construction. Failure to do so is a violation of G.S. 143-215.108 and may subject the Permittee to civil or criminal penaltie s as described in G.S. 143-215.114A and 143-
215.114B.

This permit shall be effective from June 20, 2012 until July 31, 2016, is nontransferable to future owners and operators, and shall be subject t o the conditions and limitations as specified
therein.

For PSD increment tracking purposes, PM10 emissio ns from this modification are increased by 3.96 pounds per hour and SO2 emissions from this modification are increased by 1.23 pounds per hour.

Changes have been made to the permit stipulations. The Permittee is responsible for carefully reading the entire permit and evaluating the requirements of each permit stipulation. The Permittee shall comply with all te rms, conditions, requirements, limitations and restrictions set forth in this permit. Noncompl iance with any permit condition is grounds for enforcement action, for permit termination, rev ocation and reissuance, or modification, or for denial of a permit renewal application. Specifi c changes and additions are summarized below (note: this list may not include all changes and additions):

Stipulations for 15A NCAC 2D .1100, "Control of Tox ic Air Pollutants" and 15A NCAC 2Q .0315, "Synthetic Minor Facilities" have been modified to account for the different operating scenarios associated with Kiln 4 (ID No. ES-K4).

Should you have any questions concerning this matte r, please contact Joseph Foutz at (704) 235-
2225.

Sincerely,

Ronald E. Slack Regional Air Quality Supervisor

JEF
Enclosures

c: Mooresville Regional Office
Connie Horne, Cover letter only

G:\DAQ\WPDATA\COUNTIES\ROWAN\00084\R19_PERMIT.docxNORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION

DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES

DIVISION OF AIR QUALITY

AIR PERMIT NO. 05491R19

Issue Date: June 20, 2012 Effective Date: June 20, 2012 Expiration Date: July 31, 2016 Replaces Permit: 054 91R18

To construct and operate air emission source(s) an d/or air cleaning device(s), and for the discharge of the associated air contaminants into t he atmosphere in accordance with the provisions of Article 21B of Chapter 143, General Statutes of North Carolina (NCGS) as amended, and other applicable Laws, Rules and Regulations,

Taylor Clay Products, Inc.
185 Peeler Road Salisbury, Rowan County, North Carolina Permit Class: Synthetic Minor Facility ID# 8000084

(the Permittee) is hereby authorized to construct a nd operate the air emissions sources and/or air cleaning devices and appurtenances described below:

Emission
Source ID Emission Source

Description Control System ID Control System

Description

ES-K1, ES-K2 two (2) natural gas-fired brick tunnel kilns (4.56 tons of green brick fired per hour maximum process rate and 16 million Btu per hour maximum heat input, ID No. ES-K1) and (4.56 tons of green brick fired per hour maximum process rate and 15 million Btu per hour maximum heat input, ID No. ES-K2) CD-K2 limestone, one-pass nonregenerative adsorber (68 pounds per hour minimum limestone injection rate)

ES-K3 natural gas-fired brick periodic kiln (1.03 tons of green brick fired per hour maximum process rate and 4.0 million Btu per hour maximum heat input) N/A N/APermit No. 05491R19

Page 2

Emission
Source ID Emission Source

Description Control System ID Control System

Description

ES-K4 (operating scenario 1)

ES-K4 (operating scenario 2) natural gas /petcoke-fired brick tunnel kiln (4.56 tons of green brick fired per hour maximum process rate and 16 million Btu per hour maximum heat input) combusting natural gas only and firing brick with a maximum of 10%, by weight, incinerated sewage sludge ash

natural gas/petcoke – fired brick tunnel kiln (4.56 tons of green brick fired per hour maximum process rate and 16 million Btu per hour maximum heat input)combusting a natural gaspetcoke mixture (maximum 31.8% and 350.83 pounds per hour petcoke) and firing
brick with a maximum 10% by weight incinerated sewage sludge ash N/A

CD-K4-1, CD-K4-2 N/A

lime slurry injection system (ID No. CD-K4-1) installed in series with a bagfilter (ID No. CD-K4-2, 2,800 square feet of filter area)

ES-S1 scrubbed lime storage silo (2,355 cubic feet capacity, maximum unloading rate of 2 tons per hour) CD-S1 bagfilter (240 square feet of filter area)

ES-S2 petcoke storage silo (2,500 cubic feet capacity, maximum unloading rate of 2.0 tons per hour) CD-S2 bagfilter (442.8 square feet of filter area)

ES-CB1 brick crusher conveyor belt (100 tons per hour maximum process rate) N/A N/A

ES-G1 clay grinding and screening operations (40 tons per hour maximum process rate) N/A N/A

ES-BC1 brick crusher (100 tons per hour maximum process rate) N/A N/A

in accordance with the completed application 800008 4.12A received May 15, 2012 including any plans, specifications, previous applications, and o ther supporting data, all of which are filed with t he Department of Environment and Natural Resources, Di vision of Air Quality (DAQ) and are incorporated as part of this permit.Permit No. 05491R19

Page 3

This permit is subject to the following specified conditions and limitations including any TESTING, REPORTING, OR MONITORING REQUIREMENTS:

A. SPECIFIC CONDITIONS AND LIMITATIONS

1. Any air emission sources or control devices authori zed to construct and operate above must be operated and maintained in accordance with the p rovisions contained herein. The Permittee shall comply with applicable Environmenta l Management Commission Regulations, including Title 15A North Carolina Adm inistrative Code (NCAC), Subchapter 2D .0202, 2D .0515, 2D .0516, 2D .0521, 2D .0535, 2 D .0540, 2D .1100, 2Q .0315 and 2Q
.0711.

2. PERMIT RENEWAL AND EMISSION INVENTORY REQUIREMENT - The Permittee, at least 90 days prior to the expiration date of th is permit, shall request permit renewal by letter in accordance with 15A NCAC 2Q .0304(d) and (f). Pursuant to 15A NCAC 2Q .0203(i), no permit application fee is required for renewal of an existing air permit (without a modification request). The renewal request (with AA application form) should be submitted to the Regional Supervisor, DAQ. Also, at least 90 days prior to the expiration date of this permit, the Permittee shall submit the air pollution emission inventory report (with Certification Sheet) in accordance with 15A N CAC 2D .0202, pursuant to N.C. General Statute 143 215.65. The report shall be sub mitted to the Regional Supervisor, DAQ and shall document air pollutants emitted for the 2 015 calendar year.

3. PARTICULATE CONTROL REQUIREMENT - As required by 15 A NCAC 2D .0515
"Particulates from Miscellaneous Industrial Process es," particulate matter emissions from
the emission sources shall not exceed allowable emi ssion rates. The allowable emission rates are, as defined in 15A NCAC 2D .0515, a function of the process weight rate and shall be determined by the following equation(s), where P is the process throughput rate in tons per hour (tons/hr) and E is the allowable emission rate in pounds per hour (lbs/hr).

E = 4.10 * (P) 0.67 for P <= 30 tons/hr, or
E = 55 * (P) 0.11 - 40 for P >30 tons/hr

4. SULFUR DIOXIDE CONTROL REQUIREMENT - As required by 15A NCAC 2D .0516 "Sulfur Dioxide Emissions from Combustion Sources," sulfur dioxide emissions from the combustion sources shall not exceed 2.3 pounds per million Btu heat input.

5. VISIBLE EMISSIONS CONTROL REQUIREMENT - As required by 15A NCAC 2D .0521 "Control of Visible Emissions," visible emiss ions from natural gas-fired brick kiln (ID No. ES-K1), brick kiln (ID No. ES-K2), brick crushe r (ID No. ES-BC1), conveyor belt (ID No. ES-CB1), natural gas-fired brick kiln (ID No. E S-K3), brick kiln (ID No. ES-K4), scrubbed lime storage silo (ID No. ES-S1) and petco ke storage silo (ID No. ES-S2), manufactured after July 1, 1971, shall not be more than 20 percent opacity when averaged over a six-minute period, except that six-minute pe riods averaging not more than 87 percent opacity may occur not more than once in any hour no r more than four times in any 24-hour period. However, sources which must comply with 15A NCAC 2D .0524 "New Source
Performance Standards" or .1110 "National Emission Standards for Hazardous Air Pollutants" must comply with applicable visible emi ssions requirements contained therein.Permit No. 05491R19

Page 4

6. VISIBLE EMISSIONS CONTROL REQUIREMENT - As required by 15A NCAC 2D .0521 "Control of Visible Emissions," visible emiss ions from grinding and screening operations (ID No. ES-G1), manufactured as of July 1, 1971, shall not be more than 40 percent opacity when averaged over a six-minute per iod, except that six-minute periods averaging not more than 87 percent opacity may occu r not more than once in any hour nor more than four times in any 24-hour period. However , sources which must comply with 15A
NCAC 2D .0524 "New Source Performance Standards" or .1110 "National Emission Standards for Hazardous Air Pollutants" must comply with applicable visible emissions requirements contained therein.

7. NOTIFICATION REQUIREMENT - As required by 15A NCAC 2D .0535, the Permittee of
a source of excess emissions that last for more tha n four hours and that results from a malfunction, a breakdown of process or control equi pment or any other abnormal conditions, shall:

a. Notify the Director or his designee of any such occ urrence by 9:00 a.m. Eastern time of the Division's next business day of becoming awa re of the occurrence and
describe:

i. the name and location of the facility,

ii. the nature and cause of the malfunction or breakdow n,

iii. the time when the malfunction or breakdown is first observed,

iv. the expected duration, and

v. an estimated rate of emissions.

b. Notify the Director or his designee immediately whe n the corrective measures have been accomplished.

This reporting requirement does not allow the opera tion of the facility in excess of Environmental Management Commission Regulations.

8. FUGITIVE DUST CONTROL REQUIREMENT - As required by 15A NCAC 2D .0540 "Particulates from Fugitive Dust Emission Sources," the Permittee shall not cause or allow fugitive dust emissions to cause or contribute to s ubstantive complaints or excess visible emissions beyond the property boundary. If substant ive complaints or excessive fugitive dust emissions from the facility are observed beyon d the property boundaries for six minutes in any one hour (using Reference Method 22 in 40 CF R, Appendix A), the owner or operator may be required to submit a fugitive dust plan as described in 2D .0540(f).

"Fugitive dust emissions" means particulate matter that does not pass through a process stack or vent and that is generated within plant pr operty boundaries from activities such as: unloading and loading areas, process areas stockpil es, stock pile working, plant parking lots, and plant roads (including access roads and haul ro ads).Permit No. 05491R19

Page 5

9. TOXIC AIR POLLUTANT EMISSIONS LIMITATION AND REPORT ING REQUIREMENT - Pursuant to 15A NCAC 2D .1100 "Contro l of Toxic Air Pollutants," and in accordance with the approved application for an air toxic compliance demonstration, the following permit limits shall not be exceeded:

Affected Source(s) Toxic Air Pollutant Emission
Limit

natural gas-fired brick kilns (ID Nos. ES-K1 and ES-K2) Arsenic & Compounds (total mass of elemental AS, arsine and all inorganic compounds) (ASC (7778394)) 2.48 pounds per

year

natural gas-fired brick periodic kiln (1.03 tons of green brick fired per hour maximum process rate and 4.0 million Btu per hour maximum heat input) (ES-K3) Arsenic & Compounds (total mass of elemental AS, arsine and all inorganic compounds) (ASC (7778394)) 0.28 pounds per

year

natural gas - petcoke mixture (maximum 31.8%, 350.83 pounds per hour petcoke) / natural gas-fired brick tunnel kiln (4.56 tons of green brick fired per hour maximum process rate and 16 million Btu per hour maximum heat input) firing brick with a maximum of 10%, by weight, incinerated sewage sludge ash (ES-K4) Arsenic & Compounds (total mass of elemental AS, arsine and all inorganic compounds) (ASC (7778394)) 1.24 pounds per

year

natural gas-fired brick kilns (ID Nos. ES-K1 and ES-K2) Benzene (71-43-2) 232 pounds per

year natural gas-fired brick periodic kiln (1.03 tons of green brick fired per hour maximum process rate and 4.0 million Btu per hour maximum heat input) (ES-K3) Benzene (71-43-2) 26.2 pounds per

year

natural gas - petcoke mixture (maximum 31.8%, 350.83 pounds per hour petcoke) / natural gas-fired brick tunnel kiln (4.56 tons of green brick fired per hour maximum process rate and 16 million Btu per hour maximum heat input) firing brick with a maximum of 10%, by weight, incinerated sewage sludge ash (ES-K4) Benzene (71-43-2) 115.85 pounds per

year

natural gas-fired brick kilns (ID Nos. ES-K1 and ES-K2) Cadmium Metal, elemental, unreacted (Component of CDC) (7440-43-9) 1.2 pounds

per year

natural gas-fired brick periodic kiln (1.03 tons of green brick fired per hour maximum process rate and 4.0 million Btu per hour maximum heat input) (ES-K3) Cadmium Metal, elemental, unreacted (Component of CDC) (7440-43-9) 0.135 pounds per

yearPermit No. 05491R19

Page 6

natural gas - petcoke mixture (maximum 31.8%, 350.83 pounds per hour petcoke) / natural gas-fired brick tunnel kiln (4.56 tons of green brick fired per hour maximum process rate and 16 million Btu per hour maximum heat input) firing brick with a maximum of 10%, by weight, incinerated sewage sludge ash (ES-K4) Cadmium Metal, elemental, unreacted (Component of CDC) (7440-43-9) 0.6 pounds

per year

natural gas-fired brick kilns (ID Nos. ES-K1 and ES-K2) DEHP (Di(2- ethylhexyl)phthalate) (117-81- 7) 0.438 pounds per day
natural gas-fired brick periodic kiln (1.03 tons of green brick fired per hour maximum process rate and 4.0 million Btu per hour maximum heat input) (ES-K3) DEHP (Di(2- ethylhexyl)phthalate) (117-81- 7) 0.049 pounds per day

natural gas - petcoke mixture (maximum 31.8%, 350.83 pounds per hour petcoke) / natural gas-fired brick tunnel kiln (4.56 tons of green brick fired per hour maximum process rate and 16 million Btu per hour maximum heat input) firing brick with a maximum of 10%, by weight, incinerated sewage sludge ash (ES-K4) DEHP (Di(2- ethylhexyl)phthalate) (117-81- 7) 0.219 pounds per day

natural gas-fired brick kilns (ID Nos. ES-K1 and ES-K2) Chromium (VI) Soluble Chromate Compounds (Component of CRC) (SolCR6) 0.0112 pounds per day

natural gas-fired brick periodic kiln (1.03 tons of green brick fired per hour maximum process rate and 4.0 million Btu per hour maximum heat input) (ES-K3) Chromium (VI) Soluble Chromate Compounds (Component of CRC) (SolCR6) 0.00126 pounds per day

natural gas - petcoke mixture (maximum 31.8%, 350.83 pounds per hour petcoke) / natural gas-fired brick tunnel kiln (4.56 tons of green brick fired per hour maximum process rate and 16 million Btu per hour maximum heat input) firing brick with a maximum of 10%, by weight, incinerated sewage sludge ash (ES-K4) Chromium (VI) Soluble Chromate Compounds (Component of CRC) (SolCR6) 0.00558 pounds per day

natural gas-fired brick kilns (ID Nos. ES-K1 and ES-K2) Hydrogen chloride (hydrochloric acid) (7647-01- 0) 0.155 pounds per
hour
natural gas-fired brick periodic kiln (1.03 tons of green brick fired per hour maximum process rate and 4.0 million Btu per hour maximum heat input) (ES-K3) Hydrogen chloride (hydrochloric acid) (7647-01- 0) 0.175 pounds per
hourPermit No. 05491R19

Page 7

natural gas - petcoke mixture (maximum 31.8%, 350.83 pounds per hour petcoke) / natural gas-fired brick tunnel kiln (4.56 tons of green brick fired per hour maximum process rate and 16 million Btu per hour maximum heat input) firing brick with a maximum of 10%, by weight, incinerated sewage sludge ash (ES-K4) Hydrogen chloride (hydrochloric acid) (7647-01- 0) 0.775 pounds per
hour

natural gas-fired brick kilns (ID Nos. ES-K1 and ES-K2) Hydrogen fluoride (hydrofluoric acid as mass of HF) (Component of 16984488/Fluorides) (7664-39- 3) 4.16 pounds per day

natural gas-fired brick periodic kiln (1.03 tons of green brick fired per hour maximum process rate and 4.0 million Btu per hour maximum heat input) (ES-K3) Hydrogen fluoride (hydrofluoric acid as mass of HF) (Component of 16984488/Fluorides) (7664-39- 3) 9.22 pounds per day

natural gas - petcoke mixture (maximum 31.8%, 350.83 pounds per hour petcoke) / natural gas-fired brick tunnel kiln (4.56 tons of green brick fired per hour maximum process rate and 16 million Btu per hour maximum heat input) firing brick with a maximum of 10%, by weight, incinerated sewage sludge ash (ES-K4) Hydrogen fluoride (hydrofluoric acid as mass of HF) (Component of 16984488/Fluorides) (7664-39- 3) 40.82 pounds per day

natural gas-fired brick kilns (ID Nos. ES-K1 and ES-K2) Hydrogen fluoride (hydrofluoric acid as mass of HF) (Component of 16984488/Fluorides) (7664-39- 3) 0.173 pounds per
hour

natural gas-fired brick periodic kiln (1.03 tons of green brick fired per hour maximum process rate and 4.0 million Btu per hour maximum heat input) (ES-K3) Hydrogen fluoride (hydrofluoric acid as mass of HF) (Component of 16984488/Fluorides) (7664-39- 3) 0.38 pounds per
hour

natural gas - petcoke mixture (maximum 31.8%, 350.83 pounds per hour petcoke) / natural gas-fired brick tunnel kiln (4.56 tons of green brick fired per hour maximum process rate and 16 million Btu per hour maximum heat input) firing brick with a maximum of 10%, by weight, incinerated sewage sludge ash (ES-K4) Hydrogen fluoride (hydrofluoric acid as mass of HF) (Component of 16984488/Fluorides) (7664-39- 3) 1.7 pounds per hour

a. Restrictions - To ensure compliance with the above limits, the following restrictions shall apply:Permit No. 05491R19

Page 8

i. The petcoke injection rate in the brick kiln (ID No . ES-K4) shall not exceed

350.83 pounds per hour.

ii. Emissions from brick kiln (ID No. ES-K4) shall be c ontrolled by the lime slurry injection system (ID No. CD-K4-1) installed in series with a bagfilter (ID No. CD-K4-2) when the brick kiln is combusting any amount of petcoke.

b. Reporting Requirements - For compliance purposes, w ithin 30 days after each calendar year, regardless of the actual emissions, the following shall be reported to the Regional Supervisor, DAQ:

i. Maximum hourly rate of petcoke injection in the bri ck kiln (ID No. ES-K4) for the previous 12-months period.

c. Recordkeeping Requirements - The following recordke eping requirements apply:

i. Maximum hourly rate of petcoke injection in the bri ck kiln (ID No. ES-K4).

ii. The dates when petcoke is combusted in Kiln 4 (ID N o. ES-K4).

iii. The dates when the lime slurry injection system (ID No. CD-K4-1) installed in series with a bagfilter (ID No. CD-K4-2) is oper ated.

10. LIMITATION TO AVOID 15A NCAC 2Q .0501 - Pursuan t to 15A NCAC 2Q .0315 "Synthetic Minor Facilities," to avoid the applicab ility of 15A NCAC 2Q .0501 "Purpose of Section and Requirement for a Permit," as requested by the Permittee, facility-wide hydrogen fluoride (HF), total HAPs, sulfur dioxide and particulate matter emissions shall be less than 10, 25 and 100 tons per consecutive 12-mo nth period, respectively.

a. Operations Restrictions - To ensure emissions do not exceed the limitations above, the following restrictions shall apply:

i. The brick tunnel kilns (ID Nos. ES-K1 and ES-K2) shall not operate without the concurrent operation of the limestone adsorber (ID No. CD-K2).

ii. The limestone adsorber (ID No. CD-K2) shall m aintain a minimum limestone injection rate of 68 pounds per hour.

iii. The brick kiln (ID No. ES-K4) shall not opera te without the concurrent operation of the lime slurry injection system (ID N o. CD-K4-1) and bagfilter (ID No. CD-K4-2) when combusting any amount of petc oke.

iv. The injection rate for the lime slurry inject ion system (ID No. CD-K4-1) shall be maintained at or above 0.7 gallons per minute.

v. The lime slurry for the lime slurry injection system (ID No. CD-K4-1) shall
have a lime concentration of at least 15%.Permit No. 05491R19

Page 9

vi. When Kiln 4 (ID No. ES-K4) is combusting pet coke, the Permittee shall

maintain the temperature of the brick kiln (ID No. ES-K4) exhaust at or above 190 degrees F as the exhaust enters the bagfi lter (ID No. CD-K4-2).

b. LIMESTONE ADSORBER REQUIREMENTS - Emissions fr om the natural gasfired brick kilns (ID Nos. ES-K1 and ES-K2) shall b e controlled by a limestone, one pass non-regenerative adsorber (ID No. CD-K2).

i. Inspection and Maintenance Requirements - To com ply with the provisions of this permit and ensure that emissions do not exc eed the regulatory limits, the Permittee shall perform periodic inspection and maintenance (I&M) as recommended by the manufacturer. In addition, the Permittee shall perform an annual (for each 12 month period following the i nitial inspection) inspection of the limestone adsorber system, includ ing the following:

A. Inspect and maintain the structural integrity of the limestone adsorber system (ID No CD-K2); and

B. Inspect and maintain the structural integrity of the duct work and piping leading to the limestone adsorber system (ID No. CD -K2).

ii. Monitoring Requirements

A. To ensure the proper performance of the limeston e adsorber system (ID No. ES-K2), the limestone adsorber system shall be equipped with a device to continuously measure the gauge pressure d irectly upstream of
the adsorber itself. The device shall be installed in an accessible location and shall be maintained by the Permittee, such that it is in proper working order at all times. The gauge pressure shall be mo nitored monthly and the results shall be recorded in the adsorber log b ook. (acceptable range = 0.45 to 0.55 inches water column)

B. The limestone injection rate shall be monitored at all times by the Permittee. The limestone injection rate shall be r ecorded weekly and the results shall be recorded in the adsorber log book.

iii. Recordkeeping Requirements - The results of all inspections and any
variance from manufacturer's recommendations or fro m those given in this permit (when applicable) shall be investigated with corrections made and dates of actions recorded in a log book. Records o f all maintenance and monitoring activities shall be recorded in the log book. The log book (in written or electronic form) shall be kept on-site a nd made available to DAQ personnel upon request.Permit No. 05491R19

Page 10

c. LIME SLURRY INJECTION SYSTEM REQUIREMENTS - Emis sions from Brick

Kiln 4 (ID No. ES-K4) shall be controlled by a lime slurry injection system (ID No. CD-K4-1) installed in series with a bagfilter (ID N o. CD-K4-2) when Brick Kiln 4 is combusting any amount of petcoke.

i. Inspection and Maintenance Requirements - To com ply with the provisions of this permit and ensure that emissions do not exc eed the regulatory limits, the Permittee shall perform periodic inspection and maintenance (I&M) as recommended by the manufacturer. In addition, the Permittee shall perform an annual inspection (for each 12 month period foll owing the previous inspection) of the lime slurry injection system, in cluding the following:

A. Inspect and maintain the structural integrity o f the lime slurry injection system; and

B. Inspect and maintain the structural integrity of the duct work, nozzles, and piping of the lime slurry injection system.

If the lime slurry injection system has not operate d for 1 week or more then the inspection and maintenance shall be conducted p rior to operating/restarting the lime slurry injection syst em (ID No. CD-K4-1).

ii. Monitoring Requirements

A. The system shall be equipped with a device to conti nuously measure the brick kiln's (ID No. ES-K4) exhaust gas temperature as the exhaust enters the bagfilter (ID No. CD-K4-2).

B. The flow rate of lime slurry solution shall be monitored by a flow meter installed on the lime slurry injection system . The Permittee shall record the lime slurry injection flowrate on daily basis when operating, and the flow meter shall be calibrated, as a minimu m, annually (for each 12 month period following the initial calibration) or as recommended by the manufacturer. If the lime slurry injection syst em (ID No. CD-K4-1) has not operated for 12 months or more when the flo w meter calibration is due then the calibration may be delayed. Howeve r, the calibration shall be conducted prior to operating/restarting the lime slurry injection system (ID No. CD-K4-1).

C. The Permittee shall record the lime slurry solu tion concentration used and adequately maintain the slurry concentration while it is being stored onsite.

iii. Recordkeeping Requirements - The results of all inspections and any
variance from manufacturer's recommendations or fro m those given in this permit (when applicable) shall be investigated with corrections made and dates of actions recorded in a log book. Records o f all maintenance and monitoring activities shall be recorded in the log book. The log book (inPermit No. 05491R19

Page 11

written or electronic form) shall be kept on-site a nd made available to DAQ

personnel upon request.

d. BAGFILTER REQUIREMENTS- Emissions from the bric k kiln (ID No. ES-K4), petcoke storage silo (ID No. ES-S2) and scrubbed li me storage silo (ID No. ES-S1) shall be controlled by bagfilters (ID Nos. CD-K4-2, CD-S2, and CD-S1, respectively).

i. Inspection and Maintenance Requirements -

Bagfilter Requirements - Particulate matter emissio ns shall be controlled as described in the permitted equipment list. To compl y with the provisions of this permit and ensure that emissions do not exceed the regulated limits, the Permittee shall perform periodic inspections and ma intenance (I&M) as recommended by the manufacturer. In addition, the P ermittee shall perform an annual (for each 12 month period following the i nitial inspection) internal inspection of each bagfilter system.

If Kiln 4 (ID No. ES-K4) has not combusted petcoke for 12 months or more then the Permittee may delay the internal inspectio n for the bagfilter (ID No. CD-K4-2) on the lime slurry injection system. Howev er, the internal inspection must be conducted prior to Kiln 4 combus ting petcoke or restarting the bagfilter.

If the petcoke storage silo (ID No. ES-S2) has not operated for 12 months or more then the Permittee may delay the internal insp ection for the bagfilter (ID No. CD-S2). However, the internal inspection m ust be conducted prior to operating the petcoke storage silo (ID No. ES-S2 ).

ii. Recordkeeping Requirements

A log book shall be kept on site for each control d evice and made available to Division of Air Quality personnel upon request. The Permittee shall record all inspection, maintenance and monitoring requirem ents listed above in the log book. Any variance from the manufacturer's reco mmendations shall be investigated with corrections made and date of acti ons recorded in the log
book.

11. TOXIC AIR POLLUTANT EMISSIONS LIMITATION REQUIR EMENT - Pursuant to 15A NCAC 2Q .0711 "Emission Rates Requiring a Permi t," for each of the below listed toxic air pollutants (TAPs), the Permittee has made a demonstration that facility-wide actual
emissions do not exceed the Toxic Permit Emission R ates (TPERs) listed in 15A NCAC 2Q .0711. The facility shall be operated and maintaine d in such a manner that emissions of any listed TAPs from the facility, including fugitive e missions, will not exceed TPERs listed in 15A NCAC 2Q .0711.Permit No. 05491R19

Page 12

a. A permit to emit any of the below listed TAPs sh all be required for this facility if

actual emissions from all sources will become great er than the corresponding

TPERs.

b. PRIOR to exceeding any of these listed TPERs, th e Permittee shall be responsible for obtaining a permit to emit TAPs and for demonst rating compliance with the requirements of 15A NCAC 2D .1100 "Control of Toxic Air Pollutants".

c. In accordance with the approved application, the Permittee shall maintain records of operational information demonstrating that the TAP emissions do not exceed the
TPERs as listed below:

Pollutant Carcinogens (lb/yr) Chronic

Toxicants (lb/day) Acute

Systemic
Toxicants (lb/hr) Acute

Irritants (lb/hr)

Beryllium Metal (unreacted) (Component of BEC) (7440- 41-7) 0.28

Carbon disulfide (75-15-0) 3.9

Chlorine (7782-50-5) 0.79 0.23
Dichlorobenzene(p), 1,4- (106- 46-7) 16.8

Formaldehyde (50-00-0) 0.04
MEK (methyl ethyl ketone, 2- butanone) (78-93-3) 78 22.4

Manganese & compounds (MNC) 0.63

Mercury, vapor (Component of HGC) (7439-97-6) 0.013

Methyl chloroform (71-55-6) 250 64
Nickel metal (Component of NIC) (7440-02-0) 0.13

Perchloroethylene (tetrachloroethylene) (127-18- 4) 13000

Phenol (108-95-2) 0.24
Styrene (100-42-5) 2.7

Toluene (108-88-3) 98 14.4
Xylene (mixed isomers) (1330- 20-7) 57 16.4Permit No. 05491R19

Page 13

B. GENERAL CONDITIONS AND LIMITATIONS

1. TWO COPIES OF ALL DOCUMENTS, REPORTS, TEST DATA, MO NITORING DATA, NOTIFICATIONS, REQUESTS FOR RENEWAL, AND ANY OTHER INFORMATION REQUIRED BY THIS PERMIT shall be submitted to the:

Regional Air Quality Supervisor North Carolina Division of Air Quality Mooresville Regional Office 610 East Center Avenue, Suite 301 Mooresville, NC 28115 (704) 663-1699

For identification purposes, each submittal should include the facility name as listed on the permit, the facility identification number, and the permit number.

2. RECORDS RETENTION REQUIREMENT - Any records require d by the conditions of this permit shall be kept on site and made available to DAQ personnel for inspection upon request. These records shall be maintained in a for m suitable and readily available for expeditious inspection and review. These records mu st be kept on site for a minimum of 2 years, unless another time period is otherwise spec ified.

3. ANNUAL FEE PAYMENT - Pursuant to 15A NCAC 2Q .0203( a), the Permittee shall pay the annual permit fee within 30 days of being bille d by the DAQ. Failure to pay the fee in a timely manner will cause the DAQ to initiate action to revoke the permit.

4. EQUIPMENT RELOCATION - A new air permit shall be ob tained by the Permittee prior to establishing, building, erecting, using, or operati ng the emission sources or air cleaning equipment at a site or location not specified in th is permit.

5. REPORTING REQUIREMENT - Any of the following that w ould result in previously unpermitted, new, or increased emissions must be re ported to the Regional Supervisor, DAQ:

a. changes in the information submitted in the applica tion regarding facility emissions;

b. changes that modify equipment or processes of exist ing permitted facilities; or

c. changes in the quantity or quality of materials pro cessed.

If appropriate, modifications to the permit may the n be made by the DAQ to reflect any necessary changes in the permit conditions. In no c ase are any new or increased emissions
allowed that will cause a violation of the emission limitations specified herein.

6. This permit is subject to revocation or modificatio n by the DAQ upon a determination that information contained in the application or present ed in the support thereof is incorrect, conditions under which this permit was granted have changed, or violations of conditions contained in this permit have occurred. The facilit y shall be properly operated and
maintained at all times in a manner that will effec t an overall reduction in air pollution.Permit No. 05491R19

Page 14

Unless otherwise specified by this permit, no emiss ion source may be operated without the concurrent operation of its associated air cleaning device(s) and appurtenances.

7. This permit is nontransferable by the Permittee. Fu ture owners and operators must obtain a new air permit from the DAQ.

8. This issuance of this permit in no way absolves the Permittee of liability for any potential civil penalties which may be assessed for violation s of State law which have occurred prior to the effective date of this permit.

9. This permit does not relieve the Permittee of the r esponsibility of complying with all applicable requirements of any Federal, State, or L ocal water quality or land quality control authority.

10. Reports on the operation and maintenance of the fac ility shall be submitted by the Permittee to the Regional Supervisor, DAQ at such intervals a nd in such form and detail as may be required by the DAQ. Information required in such r eports may include, but is not limited to, process weight rates, firing rates, hours of op eration, and preventive maintenance
schedules.

11. A violation of any term or condition of this permit shall subject the Permittee to enforcement pursuant to G.S. 143-215.114A, 143-215.114B, and 14 3-215.114C, including assessment of civil and/or criminal penalties.

12. Pursuant to North Carolina General Statute 143-215. 3(a)(2), no person shall refuse entry or access to any authorized representative of the DAQ who requests entry or access for purposes of inspection, and who presents appropriat e credentials, nor shall any person obstruct, hamper, or interfere with any such repres entative while in the process of carrying out his official duties. Refusal of entry or access may constitute grounds for permit revocation and assessment of civil penalties.

13. The Permittee must comply with any applicable Feder al, State, or Local requirements governing the handling, disposal, or incineration o f hazardous, solid, or medical wastes, including the Resource Conservation and Recovery Ac t (RCRA) administered by the Division of Waste Management.

14. PERMIT RETENTION REQUIREMENT - The Permittee shall retain a current copy of the air permit at the site. The Permittee must make ava ilable to personnel of the DAQ, upon request, the current copy of the air permit for the site.

15. CLEAN AIR ACT SECTION 112(r) REQUIREMENTS - Pursuan t to 40 CFR Part 68 "Accidental Release Prevention Requirements: Risk M anagement Programs Under the Clean Air Act, Section 112(r)," if the Permittee is required to develop and register a risk management plan pursuant to Section 112(r) of the F ederal Clean Air Act, then the Permittee is required to register this plan in acco rdance with 40 CFR Part 68.Permit No. 05491R19

Page 15

16. PREVENTION OF ACCIDENTAL RELEASES - GENERAL DUTY - Pursuant to Title I Part A Section 112(r)(1) of the Clean Air Act "Haza rdous Air Pollutants - Prevention of Accidental Releases - Purpose and General Duty," al though a risk management plan may not be required, if the Permittee produces, processes, handles, or stores any amount of a listed hazardous substance, the Permittee has a general du ty to take such steps as are necessary to prevent the accidental release of such substance an d to minimize the consequences of any
release. This condition is federally-enforceable only.

17. GENERAL EMISSIONS TESTING AND REPORTING REQUIREMENT S - If emissions testing is required by this permit, or the DAQ, or if the Permittee submits emissions testing to the DAQ in support of a permit application or to demonstrate compliance, the Permittee shall perform such testing in accordance with 15A N CAC 2D .2600 and follow all DAQ procedures including protocol approval, regional no tification, report submittal, and test results approval.

Permit issued this the 20 th of June, 2012.
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION

Ronald E. Slack Regional Air Quality Supervisor By Authority of the Environmental Management Commis sion

Air Permit No. 05491R19