________________________________________________________________________________ 

Mooresville Regional Office - Division of Air Quality

610 East Center Avenue, Suite 301, Mooresville, North Carolina 28115 

Phone: (704) 663-1699 \ FAX: (704) 663-7579 \ Internet: 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 Natural 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 received May 15, 2012, we are forwarding 

herewith Permit No. 05491R19 to Taylor Clay Products, 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 requirements are contained in General Condition 2 

of the General Conditions and Limitations. 

 If any parts, requirements, or limitations contained 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 contested. 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 27699-6714. The form for requesting a formal 

adjudicatory hearing may be obtained upon request from 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 through 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 informal 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 the regulations, construction of new 

air pollution sources or air cleaning devices, or modifications to the sources or air cleaning 

devices described in this permit must be covered under 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 penalties 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 to the conditions and limitations as specified 

therein. 

 For PSD increment tracking purposes, PM10 emissions 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 terms, conditions, requirements, limitations 

and restrictions set forth in this permit. Noncompliance with any permit condition is grounds 

for enforcement action, for permit termination, revocation and reissuance, or modification, or 

for denial of a permit renewal application. Specific changes and additions are summarized 

below (note: this list may not include all changes and additions): 

Stipulations for 15A NCAC 2D .1100, "Control of Toxic 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 matter, 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.docx
NORTH 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: 05491R18 

 To construct and operate air emission source(s) and/or air cleaning device(s), and for the 

discharge of the associated air contaminants into the 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 and 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/A 
Permit 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 8000084.12A received May 15, 2012 including any 

plans, specifications, previous applications, and other supporting data, all of which are filed with the 

Department of Environment and Natural Resources, Division 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 authorized to construct and operate above must 

be operated and maintained in accordance with the provisions contained herein. The 

Permittee shall comply with applicable Environmental Management Commission 

Regulations, including Title 15A North Carolina Administrative Code (NCAC), Subchapter 

2D .0202, 2D .0515, 2D .0516, 2D .0521, 2D .0535, 2D .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 this 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 NCAC 2D .0202, pursuant to N.C. 

General Statute 143 215.65. The report shall be submitted to the Regional Supervisor, DAQ 

and shall document air pollutants emitted for the 2015 calendar year. 

3. PARTICULATE CONTROL REQUIREMENT - As required by 15A NCAC 2D .0515 

"Particulates from Miscellaneous Industrial Processes," particulate matter emissions from 

the emission sources shall not exceed allowable emission 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 emissions from natural gas-fired brick kiln (ID 

No. ES-K1), brick kiln (ID No. ES-K2), brick crusher (ID No. ES-BC1), conveyor belt (ID 

No. ES-CB1), natural gas-fired brick kiln (ID No. ES-K3), brick kiln (ID No. ES-K4), 

scrubbed lime storage silo (ID No. ES-S1) and petcoke 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 periods averaging not more than 87 percent 

opacity may occur 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. 
Permit No. 05491R19 

Page 4 

6. VISIBLE EMISSIONS CONTROL REQUIREMENT - As required by 15A NCAC 2D 

.0521 "Control of Visible Emissions," visible emissions 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 period, except that six-minute periods 

averaging not more than 87 percent opacity may occur 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 than four hours and that results from a 

malfunction, a breakdown of process or control equipment or any other abnormal 

conditions, shall: 

a. Notify the Director or his designee of any such occurrence by 9:00 a.m. Eastern time 

of the Division's next business day of becoming aware of the occurrence and 

describe: 

i. the name and location of the facility, 

ii. the nature and cause of the malfunction or breakdown, 

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 when the corrective measures have 

been accomplished. 

This reporting requirement does not allow the operation 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 substantive complaints or excess visible 

emissions beyond the property boundary. If substantive complaints or excessive fugitive 

dust emissions from the facility are observed beyond the property boundaries for six minutes 

in any one hour (using Reference Method 22 in 40 CFR, 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 property boundaries from activities such as: 

unloading and loading areas, process areas stockpiles, stock pile working, plant parking lots, 

and plant roads (including access roads and haul roads). 
Permit No. 05491R19 

Page 5 

9. TOXIC AIR POLLUTANT EMISSIONS LIMITATION AND REPORTING 

REQUIREMENT - Pursuant to 15A NCAC 2D .1100 "Control 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 

year 
Permit 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 

hour 
Permit 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 controlled 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, within 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 brick kiln (ID No. ES-K4) 

for the previous 12-months period. 

c. Recordkeeping Requirements - The following recordkeeping requirements apply: 

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

ii. The dates when petcoke is combusted in Kiln 4 (ID No. 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 operated. 

10. LIMITATION TO AVOID 15A NCAC 2Q .0501 - Pursuant to 15A NCAC 2Q .0315 

"Synthetic Minor Facilities," to avoid the applicability 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-month 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 maintain a minimum limestone 

injection rate of 68 pounds per hour. 

iii. The brick kiln (ID No. ES-K4) shall not operate without the concurrent 

operation of the lime slurry injection system (ID No. CD-K4-1) and bagfilter 

(ID No. CD-K4-2) when combusting any amount of petcoke. 

iv. The injection rate for the lime slurry injection 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 petcoke, 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 bagfilter (ID No. CD-K4-2). 

b. LIMESTONE ADSORBER REQUIREMENTS - Emissions from the natural gasfired brick kilns (ID Nos. ES-K1 and ES-K2) shall be controlled by a limestone, one 

pass non-regenerative adsorber (ID No. CD-K2). 

i. Inspection and Maintenance Requirements - To comply with the provisions 

of this permit and ensure that emissions do not exceed 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 initial inspection) 

inspection of the limestone adsorber system, including 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 limestone adsorber system (ID 

No. ES-K2), the limestone adsorber system shall be equipped with a 

device to continuously measure the gauge pressure directly 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 monitored monthly and 

the results shall be recorded in the adsorber log book. (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 recorded 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 from those given in this 

permit (when applicable) shall be investigated with corrections made and 

dates of actions recorded in a log book. Records of 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 and made available to DAQ 

personnel upon request. 
Permit No. 05491R19 

Page 10 

c. LIME SLURRY INJECTION SYSTEM REQUIREMENTS - Emissions 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 No. CD-K4-2) when Brick Kiln 4 is 

combusting any amount of petcoke. 

i. Inspection and Maintenance Requirements - To comply with the provisions 

of this permit and ensure that emissions do not exceed 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 following the previous 

inspection) of the lime slurry injection system, including the following: 

A. Inspect and maintain the structural integrity of 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 operated for 1 week or more then 

the inspection and maintenance shall be conducted prior to 

operating/restarting the lime slurry injection system (ID No. CD-K4-1). 

ii. Monitoring Requirements 

A. The system shall be equipped with a device to continuously 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 minimum, annually (for each 

12 month period following the initial calibration) or as recommended by 

the manufacturer. If the lime slurry injection system (ID No. CD-K4-1) 

has not operated for 12 months or more when the flow meter calibration 

is due then the calibration may be delayed. However, 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 solution 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 from those given in this 

permit (when applicable) shall be investigated with corrections made and 

dates of actions recorded in a log book. Records of all maintenance and 

monitoring activities shall be recorded in the log book. The log book (in 
Permit No. 05491R19 

Page 11 

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

personnel upon request. 

d. BAGFILTER REQUIREMENTS- Emissions from the brick kiln (ID No. ES-K4), 

petcoke storage silo (ID No. ES-S2) and scrubbed lime 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 emissions shall be controlled as 

described in the permitted equipment list. To comply with the provisions of 

this permit and ensure that emissions do not exceed the regulated limits, the 

Permittee shall perform periodic inspections and maintenance (I&M) as 

recommended by the manufacturer. In addition, the Permittee shall perform 

an annual (for each 12 month period following the initial 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 inspection for the bagfilter (ID No. 

CD-K4-2) on the lime slurry injection system. However, the internal 

inspection must be conducted prior to Kiln 4 combusting 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 inspection for the bagfilter 

(ID No. CD-S2). However, the internal inspection must 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 device and made available to 

Division of Air Quality personnel upon request. The Permittee shall record 

all inspection, maintenance and monitoring requirements listed above in the 

log book. Any variance from the manufacturer's recommendations shall be 

investigated with corrections made and date of actions recorded in the log 

book. 

11. TOXIC AIR POLLUTANT EMISSIONS LIMITATION REQUIREMENT - Pursuant to 

15A NCAC 2Q .0711 "Emission Rates Requiring a Permit," 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 Rates (TPERs) listed in 15A NCAC 2Q 

.0711. The facility shall be operated and maintained in such a manner that emissions of any 

listed TAPs from the facility, including fugitive emissions, 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 shall be required for this facility if 

actual emissions from all sources will become greater than the corresponding 

TPERs. 

b. PRIOR to exceeding any of these listed TPERs, the Permittee shall be responsible 

for obtaining a permit to emit TAPs and for demonstrating 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 16.4 
Permit No. 05491R19 

Page 13 

B. GENERAL CONDITIONS AND LIMITATIONS

1. TWO COPIES OF ALL DOCUMENTS, REPORTS, TEST DATA, MONITORING 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 required 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 form suitable and readily available for 

expeditious inspection and review. These records must be kept on site for a minimum of 2 

years, unless another time period is otherwise specified. 

3. ANNUAL FEE PAYMENT - Pursuant to 15A NCAC 2Q .0203(a), the Permittee shall pay 

the annual permit fee within 30 days of being billed 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 obtained by the Permittee prior to 

establishing, building, erecting, using, or operating the emission sources or air cleaning 

equipment at a site or location not specified in this permit. 

5. REPORTING REQUIREMENT - Any of the following that would result in previously 

unpermitted, new, or increased emissions must be reported to the Regional Supervisor, 

DAQ: 

a. changes in the information submitted in the application regarding facility emissions; 

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

c. changes in the quantity or quality of materials processed. 

If appropriate, modifications to the permit may then be made by the DAQ to reflect any 

necessary changes in the permit conditions. In no case 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 modification by the DAQ upon a determination that 

information contained in the application or presented 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 facility shall be properly operated and 

maintained at all times in a manner that will effect an overall reduction in air pollution. 
Permit No. 05491R19 

Page 14 

Unless otherwise specified by this permit, no emission 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. Future 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 violations of State law which have occurred prior 

to the effective date of this permit. 

9. This permit does not relieve the Permittee of the responsibility of complying with all 

applicable requirements of any Federal, State, or Local water quality or land quality control 

authority. 

10. Reports on the operation and maintenance of the facility shall be submitted by the Permittee 

to the Regional Supervisor, DAQ at such intervals and in such form and detail as may be 

required by the DAQ. Information required in such reports may include, but is not limited 

to, process weight rates, firing rates, hours of operation, 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 143-215.114C, 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 appropriate credentials, nor shall any person 

obstruct, hamper, or interfere with any such representative 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 Federal, State, or Local requirements 

governing the handling, disposal, or incineration of hazardous, solid, or medical wastes, 

including the Resource Conservation and Recovery Act (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 available 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 - Pursuant to 40 CFR Part 68 

"Accidental Release Prevention Requirements: Risk Management 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 Federal Clean Air Act, then the 

Permittee is required to register this plan in accordance 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 "Hazardous Air Pollutants - Prevention of 

Accidental Releases - Purpose and General Duty," although 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 duty to take such steps as are necessary to 

prevent the accidental release of such substance and to minimize the consequences of any 

release. This condition is federally-enforceable only.

17. GENERAL EMISSIONS TESTING AND REPORTING REQUIREMENTS - 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 NCAC 2D .2600 and follow all DAQ 

procedures including protocol approval, regional notification, report submittal, and test 

results approval. 

Permit issued this the 20th of June, 2012. 

NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION 

 

Ronald E. Slack 

Regional Air Quality Supervisor 

By Authority of the Environmental Management Commission 

Air Permit No. 05491R19