DAQ-2024-011217

1

DAQC-1056-24
Site ID 10423 (B2)

MEMORANDUM

TO: FILE – INTERSTATE BRICK COMPANY

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Robert Haynes, Environmental Scientist

DATE: October 16, 2024

SUBJECT: Title V Annual Compliance Certification Receipt/Review,
FRS ID # UT0000004903500200

REPORT RECEIVED/DUE DATE: October 9, 2024 / October 10, 2024

TITLE V PERMIT: #3500200002

DATE OF LAST
PERMIT REVISION: February 19, 2024

CERTIFICATION PERIOD: September 23, 2023 – September 23, 2024
FACILITY REPORT
COMPLIANCE STATUS: Intermittent

REPORT EVALUATION:

• Was report submitted on time? Yes
• Did report identify status of compliance for each condition? Yes
• Was compliance status marked as continuous/intermittent for each condition? Yes
• Did report identify method used to determine compliance with each condition? Yes
• Was report signed and properly certified by responsible official? Yes
• Were exceedances/excursions reported? Yes
• Were deviations reported? Yes

II.B.3.b Kiln 4 excess emissions, scrubber down for maintenance March 20, 2024.
Deviation reported March 22, 2024, NFA.

CURRENT RECOMMENDATION: The report appears to meet the requirements of the Title V
operating permit condition I.L.

ATTACHMENTS: Annual Compliance Certification Report.

8 0 .
() INTERSTATE"BRIcK
TO:
FROM:
DATE:
RE:
r*tnr P,ABCO'
Executive Secretary
Utah Air Quality Board
P.O. Box 144820
salt Lake city, uT
84714-4820
lnterstate Brick Company
9780 South 5200 West
West Jordan, UT 84081-5625
Septernber 23,2024
Annual Compllance Certlflcation for Permlt #3500200002
-6
DEPARTMENT OF
ENVIIIONMENTAL OUAIITY,
1)an d de-lt t)orti
ocT - 9 n24
DIVIS]ON OF AIR OUALTTY
Under Operating Permit Provision I.L and Utah Administrative Code (UAC) R307415-6c(5), the following compliance
certification is submified. This certification covers the period of operations from September 23, 2023, to September 23, 2024:
Term Description of permit provision Method used
to determine
compliance
status
Was
compliance
during the
permit period
continuous,
intermittent
or
undetermined
Other facts relevant to
compliance status,
including any and all
deviations
1A Federal Enforcement Continuous
1B Permitted Activity(ies)Continuous
1.C.7 Duty to Comply with all conditions of the
permlt
Continuous
t.c,2 Not an excuse ln permit action to say
halting or reducing permitted activity
would have been necessary to maintain
compliance.
Continuous
t.c.3 The source shallfurnish any information
that may be requested by the Executive
Secretary.
Continuous
1.C.4 Continuous
1.D.1 Fixed term of permit and expiration Continuous
1.D.2 for renewal Continuous submitted 3124t2023
1.D.3 tion for renewal after due date Continuous
7,D,4 Permit expiration and right to operate Continuous
Parle 1lB
REVIEWEDInitials:Date: Oct 10, 2024Compliance Status: Non-compliantFile #: 10423 (B2)Comment: Revise- For II.B.3.b is the Kiln 4 scrubber required maintenance, or is it a breakdown?
1,,E Timely application renewal shie ld Continuous
L,F lf parts of permit found invalid the rest
remains valid
Continuous
r.G.1 The source shall pay an annual emissions
fee consistent with R307-415-9 (R307-
41s-6a(7)).
Continuous
t.G.2 "fee shall be due on October 1 ofeach
calendar year or45 days after the source
receives notice of the amount of the fee"
2022Fee was
due on
October 1,
2023.
Continuous 2023 Emissions Fee was
paid and delivsred on
9/30/2024
1.H Permit conveys on property rights Continuous
1.1 Continuous
1.J.1.a Continuous
1.J.1,b Continuous
7.t.7.c Continuous
1.J.1.d Continuous
\).2 Continuous
1.K Continuous
1.1.1 Continuous
LL.1.a The permittee shallsubmit to the
Director an annual compliance
certificatio n, ce rtif,/ing co m plia nce with
the terms and conditions contained in
this permit....,
Continuous Annual Cornpliance
Certifi cation for Interstate
Brick was
submitted on
October 2nd 2024
1.1.1.b Continuous
1.1.1.c Continuous
1.1.1.d Continuous
t.1.2 The permittee shallalso send all
compliance certifications to EPA, Region
vill.
Environmental Protectlon Agency, Region
Vlll, Office of Enforcement, Compliance
and Environmental Justice (mail code
SENF) 1595 Wynkoop Street, Denver, CO
80202-7t29
Continuous
1.M.1.
a
Continuous
1.M.1.
b
Continuous
1..M.2.
a
Continuous
1..M.2.
b
Continuous
1.M.2,c Continuous
1.M.2,
d
Continuous
t']age.2l8
1.N.1 Continuous
1.N.2.a Continuous
1.N.2.b Continuous
1.N.2.c Continuous
1. N.2,d Continuous
1.N.3 Continuous
1.N.4 Continuous
1.O Continuous
1.P Continuous
1.Q Continuous
1.R Continuous
l.S.1.a The records of all required monitoring
data and support informatlon shallbe
retained by the permittee for a period of
at least five years from the date ofthe
monitoring sam ple, measurement,
report, or a pplication.
Records as
specified in
the permit
Continuous
1.S.1.b,
L
Continuous
1.S.1.b.
2
Continuous
1.S.1,b.
3
Continuous
1,S.1.b,
4
Continuous
1.S.1.b.
5
Continuous
1.S.1.b.
6
Continuous
1.S.1.c Continuous
l.S.2,a Did the permittee submit monitoring
reports every six rnonths, or more
frequently if specified in Section ll, and
were all instances of deviation from
permit requirements clearly identified in
the monitorins renorts?
Continuous The Six Month
Monitoring Reports were
submitted on March 22nd,
2024, and October 2nd,
2024.
1.S.2.b Continuous
r.S.2.c The Director shall be notified promptly of
any deviations from permit
requirements.
Deviation
Reports are
due within t4
days of
occurrence
Continuous Deviation Report for
Excess Ernissions on
March 2oth,2}24
was submitted on
March 22"d.2024.
1.S,3.a Continuous
r..s.3.b Continuous
1.T.1.a Continuous
1.T.1.b Continuous
1.T.1,c Continuous
1.T.1.d Continuous
1.T.2 Continuous
1.T.3 Continuous
t.u Did the permittee submit the inventory
required by R307-1.50 in accordance with
the requirements of that rule? (This
covers R307-150, 155 and 158 if listed in
permit) ll.B,x Each provision in Section
ll.B, including each monitoring, record
keeplne, and reporting reouirement.
2023
Emissions
Inventory was
due April i5,
2024,
Continuous Inventory was submitted
to UDAQ on April5,
2024.
1.V Continuous
ll.B.L.a "Plant wide production/consumption
shall not exceed:
1) 2,880 tons raw clay consumption per
rolling 24-hr perlod.
21393,236 tons of brick produced in Line
#3 and Line fl4 combined per rolllng L2-
month period.
31512,582 tons of brick produced plant-
wide per rolling 12 month period"
Clay
Preparation
production
report and
Mass Balance
plan.
Continuous
il,8.1.b "Visible emissions from the following
shall not exceed
1) All screens - 10% opacity (no
screens are open to the outside
ai4
2l All conveyor transfer points -
10% opacity.
3) All baghouses- LO% opacity
4) All buildings enclosing crushers -
10% opacity
5) All crushers - 15% opacity
All other points onsite - 2A% opacity,"
Fugitive Dust
Control Plan.
Certified
Opacity
Readers.
Continuous
ll.B.1.c The Moisture content of clay was
maintained at an average of no less than
4.0Yoby weight.
A hand-held
moisture
meter was
used to veriff
the moisture
content ofthe
clays.
Continuous
ll.B.1.c.
2
The moisture meter was calibrated
biannually according to the manufacturer
as per a maintenance contract.
Service
records and
invoices from
vendor.
Continuous
P;rgt:418
il.8.1.d Plant-wide emissions of VOCs from the
brick manufacturlng plant and associated
operations shall not exceed 14,87 tons
oer rolline 12-month period for VOCs.
Rolling l2-
rnonth total
VOC log.
Continuous
ll.B.1.e Plant-wide emissions of HAPs from the
brick manufacturing plant and associated
operations shall not exceed: 7.2 tons per
rolling l2-month period for HCL, 6.7 tons
per rolling 12-month period for HF, 7,0
tons per rolling l2-month period for
miscellaneous HAPs, and 18.2 tons per
rolling 12-month period for all HAPs
combined,
Mass balance
plan and stack
testing.
Continuous
il.8.1.f Fugitive Dust. (1)the permittee shall
submit and abide by a fugitive dust
control plan.." (Origin: Permit
#3500200001
Opacity caused by fugitive dust shall not
exceed 10% at the property boundary
and 20% on site. Vehicle speeds on haul
roads shall be limited to 15 rnph within
the plant and in vicinity of the crusher,
and 25 mph between the plant and the
paved highway. Speed limit signs shall be
posted at the entrance to the active haul
road area,"
Fugitive Dust
control plan
log(s) (water
truck log,
wind speed
log), speed
limit signs.
Continuous
ll.B.2.a All exhaust air from l(iln #3 shall be
routed through the wet scrubber before
being vented to the atmosphere.
Scrubber
operating log
Continuous
il.8.2.b Emissions from the Kiln #3 Scrubber
Tunnel did not exceed
Total PM2.5*.....8.66 lb/hr (l-hr average).
PM10....8.56 lblhr (l-hr average)
NOx....5.07 lb/hr (1-hr average)
SO2,...8.09 lb/hr (1-hr average)
Total Fluorides... L.77 lb/hr (1-hr average)
*lncluding front half and back half
condensables
as per authority granted under R307-401-
8(1)(a)tBACTl and condition originated in
Permit #3500200001.
Mass balance
log and
Annual Stack
testing
Continuous
il.8.2.b
,t
Stack testing shall be performed...
PM10 and PM2.5,..every three calendar
yea rs
NOx....every three calendar years
SO2...every ca lendar year
Total Fluorides....every five years based
on the date ofthe last test.
Stack Testing
Reports
Continuous Stack Testing Report
Subrnitted September 5th
2024.
Pagr:518
ll.B.2.c Emissions from the Line #3 Baghouse
shall not exceed (1)Total PM2.5,..0.18
lblhr and 0.016 gralns/dscf (1-hr
average); and
(2) PM10....0.18 lb/hr and 0.016
grains/dscf (1-hr ave rage).
Stack testing
perfonned
every three
years,
Continuous
ll.B.2.c.
1
Stack testing shall be performed...
Every 3 calendar years
Stack test
results
Continuous
il.8.2.d The Line #3 tunnel kiln shall not exceed
17.92 tons of product per hour.
Mass balance
production
records
Continuous
ll.B.2.e Clay Prep for Line #3 shall not exceed
6,240 hours of operation per rolling 12-
month period (does not include l(iln #3
operatine hours).
Mass balance
ptoduction
records
Continuous
il.B.2.f Naturalgas shall be used in Klln #3 with
propane as a backup,
Fuel usage
records.
Continuous
ll.B.2.g A rninimum pressure drop for Line #3
scrubber shall be 0.1. inches w,g.
Scrubber
operatins los
Continuous
il.8.2.h The Line 3 scrubber fluid shall be
maintained between 5-9 pH
Scrubber
operatins los
Continuous
il.8.2.i The minimum flow rate of the Line #3
scrubber was 200 gallons per minute
Scrubber
operatins loe
Continuous
il.8.2,i,
L
Flowmeter for continuous measurement
of flow rate shall be installed, calibrated,
ma intained, and operated.
Scrubber
operating log
and annual
calibration
record.
Continuous
ll.B.3.a All exhaust air from Kiln #4 process
streams shall be routed through the wet
scrubber before being vented off to the
atmosphere
Scrubber
operating log
Continuous
il.8.3.b Emissions from the Kiln #4 Scrubber
Tunnel shall not exceed
Total PM2.5*.....3.97 lblhr (1-hr average).
PM10..,.3.97 lblhr (1-hr average)
NOx....10.52 lb/hr (1-hr average)
SO2....5.87 lb/hr (1-hr average)
Total Fluorides... 3.25 lb/hr (L-hr average)
Mass balance
log and
Annual Stack
testing
Intern:ittent Ifiln 4 Scrubber Excess
Emissions due to required
maintenance to keep the
scrubber in operation on
March 20il',2024 from
Tamto 4pm.
il,8.3.b
.1
Stack testing shall be performed...
PML0 and PM2.5...every three calendar
years
NOx,,..every three calendar years
SO2...every calendar yea r
Total Fluorides.,..every five years based
on the date of the last test.
Stack testing
records
Continuous
618
ll.8.3.c Emissions from the Llne #4 baghouse
shall not exceed...
Total PM2.5 ,..0,34 lb/hr and 0.0L6
grains/dscf (1-hr average),
PM10..0.34 lb/hr (dry filterable
particulate only), and 0.016 grains/dscf
(1-hr, average).
Stack testing Continuous
ll.B.3.c.
L
Stack testing shall be performed...
Every 3 calendar years
Stack test
records
Continuous
il.8.3.d The Line 4 tunnel kiln production shall
not exceed 26.97 tons of product per
hour averaged over a rolling Z4-hour
period.
Mass balance
log
Continuous
ll.B.3.e.
7
Clay Prep for Line #4 shall not exceed
6,240 hours of operation per rolling 12-
month perlod (does not include l(iln #3
operatins hours).
Mass balance
production
records
Continuous
il.8.3.f Natural gas shall be used in Kiln #4 with
propane as a backup.
Fuel usage
records.
Continuous
ll.B.3.g A minimum pressure drop for Line #4
scrubber shall be 2.0 inches w.g.
Scrubber
ooeratins lop
Continuous
il.8.3.h The Line 4 scrubber fluid shall be
maintained between 5-9 pH
Scrubber
ooeratins los
Continuous
il.8.3.i The minimum flow rate of the Line #4
scrubber was 600 gallons per minute
Scrubber
ooeratins los
Continuous
il.8.3.i.
1
Flowmeter for continuous measurement
of flow rate shall be installed, calibrated,
maintained, and operated.
Scrubber
operating 1og
and annual
calibration
record.
Continuous
il.B.4 All exhaust from the primary crusher
building shall be routed through the
Primary Crusher Baghouse before being
vented to atmosphere.
Baghouse
operating log
Continuous
il.8.4,b Emissions from the Primary Crusher
Baghouse Vent shall not exceed.... Total
PM2.5 and PM10: 0.56 lblhr and 0.010
erains/dscf {1-hr averape}
Stack testing
results
Continuous
lt.B.4.b
,7
Stack testing shall be performed.,,
Every 3 calendar years
Stack test
reoorts
Continuous
ll.B.4.c The minimum pressure drop for the
Primary Crusher Baghouse shall be:
(A) 2,0 inches/w.g. when using
polyester felt; or
(B) 0.4 in inches/w.g. when using
PTFE membrane.
Bag house
operating log
Continuous
7lB
ll.B.5.a Gasoline Storage Tank - 40 CFR 63
Subpart CCCCCC
For each gasoline storage tank with a
throughput less than 1.0,000 gallons per
month the permittee allow gasoline to be
handled in a mannerthat would not
result in vapor releases to the
atmosphere for extended periods of
time..........
Gasoline
Tanks
inspected
monthly.
Continuous
il.B.6 Degreasers:
The permittee shall ensure that the
following conditions are met:
(1) All solvent degreasers are equipped
with a cover which remains closed except
during actual parts cleanlng. The cover is
designed so it can easily be operated with
one hand.
(2) internal draining racks are installed
and are used. Parts were enclosed under
cover whlle draining.
(3) waste or used solvent shall be stored
in covered containers.
(4) solvent cleaning equipment shall be
maintained in good operatin8 condition
and there were no leaks.
(5) procedures for operation are posted.
(6) The solvent volatility is less than 4.3
kPa
(7) solvent spray strearn pressure is such
that it does not cause excessive
solashine.
Degreasers
are inspected
monthly.
Continuous
reasonable inquiry, I certifo that the statements and information in
Name and Title of cial for the Source
ln accordance with Operating Permit provision l.K and UAC R307-415-5d and based on information and belief formed after
this document are true, accurate, and complete.
l',rrt,8l8
REVIEWEDInitials:Date: Oct 10, 2024Compliance Status: Non-compliantFile #: 10423 (B2)Comment: Revise- is the Kiln 4 scrubber requiredmaintenance, or is it a breakdown?